Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Disallowance under section 14A cannot exceed the exempt income earned in the relevant year, so a higher Rule 8D disallowance was not sustainable where the assessee had already made a suo motu disallowance. The Tribunal upheld restriction of the disallowance to the amount already offered by the assessee. On CSR-related donations, it held that Explanation 2 to section 37(1) only denies CSR expenditure as business deduction and does not bar a separate deduction under section 80G if the statutory conditions are met. Approved donee status and banking-channel payments supported the claim, so the deduction was upheld.
Disallowance under section 14A cannot exceed the exempt income earned in the relevant year, so a higher Rule 8D disallowance was not sustainable where the assessee had already made a suo motu disallowance. The Tribunal upheld restriction of the disallowance to the amount already offered by the assessee. On CSR-related donations, it held that Explanation 2 to section 37(1) only denies CSR expenditure as business deduction and does not bar a separate deduction under section 80G if the statutory conditions are met. Approved donee status and banking-channel payments supported the claim, so the deduction was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
