Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Appeal by assessee was partly allowed. ITAT held that separate TP benchmarking for royalty was unwarranted when TNMM was accepted for other international transactions; assessee's TNMM-based ALP for royalty was upheld. Exemption u/s 10AA and deduction u/s 80JJAA, disallowed by CPC for a return filed a few hours late due to portal glitches, were sustained as valid, the due-date condition not being applicable for A.Y. 2018-19. Disallowance u/s 14A as made by AO was upheld, but ITAT directed that such disallowance not be added while computing book profits u/s 115JB. Deduction u/s 35(2AB), correction of double taxation of LTCG, and recomputation of interest u/s 234C were remitted to AO/JAO for verification and fresh computation.
Appeal by assessee was partly allowed. ITAT held that separate TP benchmarking for royalty was unwarranted when TNMM was accepted for other international transactions; assessee's TNMM-based ALP for royalty was upheld. Exemption u/s 10AA and deduction u/s 80JJAA, disallowed by CPC for a return filed a few hours late due to portal glitches, were sustained as valid, the due-date condition not being applicable for A.Y. 2018-19. Disallowance u/s 14A as made by AO was upheld, but ITAT directed that such disallowance not be added while computing book profits u/s 115JB. Deduction u/s 35(2AB), correction of double taxation of LTCG, and recomputation of interest u/s 234C were remitted to AO/JAO for verification and fresh computation.
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