Distributors' Commissions and CSR Donations Upheld: Tax Tribunal Provides Clarity on Deduction Principles and Transfer Pricing Adjustments

ITAT adjudicated multiple taxation issues: (1) Rejected transfer pricing adjustment on commission paid to local distributors, finding it not an AMP expense and consistent with prior assessment years. Tribunal set aside TPO/AO/DRP order and deleted the adjustment. (2) Allowed deduction under Section 80G for CSR contributions, holding that Explanation 2 to Section 37 cannot deny deductions for donations made by charitable trusts registered under 80G. (3) Remanded the 80G deduction claim back to AO for verification, directing assessee to submit donation receipts and substantiate eligibility conditions. The ITAT's rulings emphasized procedural fairness and consistent interpretation of tax provisions. .....

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