Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
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