Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
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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