Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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The Tribunal held that the interest on overdue receivables from associated enterprises could not be benchmarked at LIBOR plus 450 basis points because no justification was given for that rate, and directed recomputation at LIBOR plus 200 basis points. The ESOP-cost dispute was treated as infructuous since no transfer pricing adjustment survived in the ITeS segment. On CSR donations, it held that contributions made to trusts eligible under section 80G were not barred merely because they formed part of CSR expenditure, and directed allowance of the deduction where the assessee had not claimed section 37 relief. Interest under sections 234A and 234C was left to be recomputed in accordance with law.
The Tribunal held that the interest on overdue receivables from associated enterprises could not be benchmarked at LIBOR plus 450 basis points because no justification was given for that rate, and directed recomputation at LIBOR plus 200 basis points. The ESOP-cost dispute was treated as infructuous since no transfer pricing adjustment survived in the ITeS segment. On CSR donations, it held that contributions made to trusts eligible under section 80G were not barred merely because they formed part of CSR expenditure, and directed allowance of the deduction where the assessee had not claimed section 37 relief. Interest under sections 234A and 234C was left to be recomputed in accordance with law.
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