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    <title>2025 (4) TMI 1801 - ITAT DELHI</title>
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    <description>CSR-related donations were held not to be barred from deduction under section 80G merely because the outlay arose from a statutory CSR obligation, as the deduction depends on the independent conditions of section 80G and those conditions were otherwise satisfied. The MEIS duty reward scrip receipt claim, not raised in the return, was held fit for appellate examination and remitted for fresh consideration. The enhanced deduction claim under section 80-IA based on market price of electricity and additional evidence was also restored for verification. On transfer pricing, notional interest on outstanding receivables from AEs could not be adjusted without factoring in working capital effects already relevant to comparability, so the matter was set aside for reconsideration with working capital adjustment.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468238</link>
      <description>CSR-related donations were held not to be barred from deduction under section 80G merely because the outlay arose from a statutory CSR obligation, as the deduction depends on the independent conditions of section 80G and those conditions were otherwise satisfied. The MEIS duty reward scrip receipt claim, not raised in the return, was held fit for appellate examination and remitted for fresh consideration. The enhanced deduction claim under section 80-IA based on market price of electricity and additional evidence was also restored for verification. On transfer pricing, notional interest on outstanding receivables from AEs could not be adjusted without factoring in working capital effects already relevant to comparability, so the matter was set aside for reconsideration with working capital adjustment.</description>
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