Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
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