Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Transfer pricing adjustment on intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after hearing. CSR-related donation was held eligible for section 80G deduction since section 37 bar does not extend to Chapter VI-A except specified funds; deduction was allowed. - ITAT
Transfer pricing adjustment on intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after hearing. CSR-related donation was held eligible for section 80G deduction since section 37 bar does not extend to Chapter VI-A except specified funds; deduction was allowed. - ITAT
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