Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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