Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
The ITAT held that once TNMM benchmarking of logistics services had been accepted on a combined basis, the same cost elements could not be separately benchmarked again for royalty and GAM charges, so those additional transfer pricing adjustments were deleted. It restored the working capital adjustment to the AO/TPO for fresh consideration on the basis of the material already furnished. On CSR-related donations, the Tribunal held that disallowance under Explanation 2 to section 37(1) does not bar deduction under section 80G where the donation otherwise qualifies, and allowed the claim. TDS/TCS credit and the section 43B issue were remanded for verification and fresh decision.
The ITAT held that once TNMM benchmarking of logistics services had been accepted on a combined basis, the same cost elements could not be separately benchmarked again for royalty and GAM charges, so those additional transfer pricing adjustments were deleted. It restored the working capital adjustment to the AO/TPO for fresh consideration on the basis of the material already furnished. On CSR-related donations, the Tribunal held that disallowance under Explanation 2 to section 37(1) does not bar deduction under section 80G where the donation otherwise qualifies, and allowed the claim. TDS/TCS credit and the section 43B issue were remanded for verification and fresh decision.
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