https://www.taxtmi.com/caselaws?id=752109 The ITAT Delhi ruled on three key issues. First, regarding TP adjustments under Section 92BA read with 92CA and 80IA(10), the tribunal found that the AO failed to establish the existence of arrangements between eligible units and associated enterprises based solely on higher operating profits. The matter was remanded to verify additional evidence regarding market pricing of purchase transactions. Second, on Section 80G deductions for CSR expenses, the tribunal held that contributions to Section 12A registered bodies are deductible under Section 80G despite CSR expense restrictions under Section 37, as these provisions are mutually exclusive except for specific exclusions. Third, regarding weighted deductions under Section 35(2AB), the tribunal upheld that deductions are limited to amounts approved by prescribed authorities per substituted Rule 6(7A). en-us Wed, 01 May 2024 00:00:00 +0530 Thu, 02 May 2024 17:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752109 The ITAT Delhi ruled on three key issues. First, regarding TP adjustments under Section 92BA read with 92CA and 80IA(10), the tribunal found that the AO failed to establish the existence of arrangements between eligible units and associated enterprises based solely on higher operating profits. The matter was remanded to verify additional evidence regarding market pricing of purchase transactions. Second, on Section 80G deductions for CSR expenses, the tribunal held that contributions to Section 12A registered bodies are deductible under Section 80G despite CSR expense restrictions under Section 37, as these provisions are mutually exclusive except for specific exclusions. Third, regarding weighted deductions under Section 35(2AB), the tribunal upheld that deductions are limited to amounts approved by prescribed authorities per substituted Rule 6(7A). Case-Laws Income Tax Wed, 01 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752109