Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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.
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