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One-time settlement paid to contractors was treated as revenue business expenditure incurred wholly and exclusively for business purposes; the Tribunal accepted that the contractors remained responsible for their workers, tax was deducted at source, and the payments were made to avoid disruption during restructuring, so the full deduction was allowed and the four-fifths disallowance deleted. The disallowance linked to exempt income was remitted because the Assessing Officer proceeded on the mistaken assumption that no suo motu disallowance existed, while the assessee had not fully supported its computation, requiring fresh examination after considering the computation and further material. The treaty-rate claim on dividend distribution tax was admitted as a pure legal ground and remitted for decision after the Supreme Court's final ruling on the controversy.
One-time settlement paid to contractors was treated as revenue business expenditure incurred wholly and exclusively for business purposes; the Tribunal accepted that the contractors remained responsible for their workers, tax was deducted at source, and the payments were made to avoid disruption during restructuring, so the full deduction was allowed and the four-fifths disallowance deleted. The disallowance linked to exempt income was remitted because the Assessing Officer proceeded on the mistaken assumption that no suo motu disallowance existed, while the assessee had not fully supported its computation, requiring fresh examination after considering the computation and further material. The treaty-rate claim on dividend distribution tax was admitted as a pure legal ground and remitted for decision after the Supreme Court's final ruling on the controversy.
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