Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Provision for repair of unserviceable spare parts in an airline business was treated as an allowable business expenditure rather than a mere contingent liability, because the Tribunal found the inventory and repair outgo to be part of the ordinary recurring business cycle and accepted estimation-based provisioning under Bharat Earth Movers and Chainrup Sampatram. The disallowance was deleted, subject to proper computation in accordance with law. The claim for provision for obsolescence of Bid & Win inventory was rejected for the year under appeal, as the Department stated it had been accepted in the succeeding assessment year. Other disallowance grounds were not pressed before the CIT(A).
Provision for repair of unserviceable spare parts in an airline business was treated as an allowable business expenditure rather than a mere contingent liability, because the Tribunal found the inventory and repair outgo to be part of the ordinary recurring business cycle and accepted estimation-based provisioning under Bharat Earth Movers and Chainrup Sampatram. The disallowance was deleted, subject to proper computation in accordance with law. The claim for provision for obsolescence of Bid & Win inventory was rejected for the year under appeal, as the Department stated it had been accepted in the succeeding assessment year. Other disallowance grounds were not pressed before the CIT(A).
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