Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The note addresses whether CSR-related donations disallowed as business expenses under Explanation 2 to section 37(1) can nonetheless qualify for deduction under section 80G. The Tribunal applied the principle that Chapter VI-A deductions operate independently and held that a donation meeting the statutory conditions for charitable deductions and routed through banking channels is eligible under section 80G despite being excluded as a business deduction; accordingly, the departmental addition was deleted. The reasoning relied on coordinate-bench precedents and the donees' approval status under the statutory scheme.
The note addresses whether CSR-related donations disallowed as business expenses under Explanation 2 to section 37(1) can nonetheless qualify for deduction under section 80G. The Tribunal applied the principle that Chapter VI-A deductions operate independently and held that a donation meeting the statutory conditions for charitable deductions and routed through banking channels is eligible under section 80G despite being excluded as a business deduction; accordingly, the departmental addition was deleted. The reasoning relied on coordinate-bench precedents and the donees' approval status under the statutory scheme.
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