Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
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