Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
ITAT held that deduction for additional employee cost is allowable for three assessment years under the statutory scheme and upheld CIT(A)'s allowance. It deleted interest disallowance under section 14A/Rule 8D because interest-free own funds exceeded exempt investments and Rule 8D's mechanical computation was unsustainable without AO's cogent dissatisfaction. The Tribunal found write back of creditors reflected in profit before tax, disallowing a fresh addition. AJIO marketing outlays were treated as revenue expenditure despite Ind AS capitalisation. Section 80G deductions operate independently of section 37(1) CSR disallowance and were allowed. Foreign tax credit claim filed before assessment completion was remitted for verification and grant by the AO.
ITAT held that deduction for additional employee cost is allowable for three assessment years under the statutory scheme and upheld CIT(A)'s allowance. It deleted interest disallowance under section 14A/Rule 8D because interest-free own funds exceeded exempt investments and Rule 8D's mechanical computation was unsustainable without AO's cogent dissatisfaction. The Tribunal found write back of creditors reflected in profit before tax, disallowing a fresh addition. AJIO marketing outlays were treated as revenue expenditure despite Ind AS capitalisation. Section 80G deductions operate independently of section 37(1) CSR disallowance and were allowed. Foreign tax credit claim filed before assessment completion was remitted for verification and grant by the AO.
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