https://www.taxtmi.com/caselaws?id=783621 On transfer pricing for royalty to an AE, the ITAT held that where the assessee had executed a unilateral APA with CBDT covering the royalty transaction and had filed a modified return enhancing income, the AO must give effect to the APA while determining the arm's length price; the AO was directed to pass the order accordingly, displacing the DRP-confirmed upward adjustment. On deduction under s. 80G for donations claimed as CSR expenditure, the ITAT held that s. 80G deduction is not barred merely because the expenditure is also CSR, following binding HC/ITAT precedents; the AO's disallowance was deleted. en-us Fri, 21 Nov 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783621 On transfer pricing for royalty to an AE, the ITAT held that where the assessee had executed a unilateral APA with CBDT covering the royalty transaction and had filed a modified return enhancing income, the AO must give effect to the APA while determining the arm's length price; the AO was directed to pass the order accordingly, displacing the DRP-confirmed upward adjustment. On deduction under s. 80G for donations claimed as CSR expenditure, the ITAT held that s. 80G deduction is not barred merely because the expenditure is also CSR, following binding HC/ITAT precedents; the AO's disallowance was deleted. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783621