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...
Disallowance of AMP payments as non-genuine: tribunal accepted appellate authority's finding that vendors were regular, turnover corroborated payments and AO raised no material to rebut genuineness - disallowance deleted. Disallowance of salaries paid via credit-notes: tribunal held on facts that deployment of staff at retailers for product promotion is a legitimate marketing model, credit-notes and payments were substantiated and profits remained healthy - disallowance deleted. Apportionment of AMP between assessee and contract manufacturers claiming 80IC benefits: tribunal found brand, formula and marketing exclusively controlled by assessee and prior assessments accepted ALP - no reallocation warranted. Section 14A/Rule 8D: tribunal restricted disallowance to investments that yielded exempt income, following binding precedents - addition limited accordingly. - ITAT
Disallowance of AMP payments as non-genuine: tribunal accepted appellate authority's finding that vendors were regular, turnover corroborated payments and AO raised no material to rebut genuineness - disallowance deleted. Disallowance of salaries paid via credit-notes: tribunal held on facts that deployment of staff at retailers for product promotion is a legitimate marketing model, credit-notes and payments were substantiated and profits remained healthy - disallowance deleted. Apportionment of AMP between assessee and contract manufacturers claiming 80IC benefits: tribunal found brand, formula and marketing exclusively controlled by assessee and prior assessments accepted ALP - no reallocation warranted. Section 14A/Rule 8D: tribunal restricted disallowance to investments that yielded exempt income, following binding precedents - addition limited accordingly. - ITAT
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