Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Year-end provisions for identified resident professional fees are treated as amounts on which tax must be deducted at source when the liability is created, so disallowance can arise if TDS is not deducted at that stage. Where deducted tax is deposited on or before the return-filing due date, the related expenditure is allowable for that year; if deposit is later, allowance shifts to the year of actual payment. Payments to offshore lawyers require examination of chargeability in India and any treaty protection before withholding is determined. A provision later reversed because the amount was not payable is treated as an unascertained liability and is not allowable.
Year-end provisions for identified resident professional fees are treated as amounts on which tax must be deducted at source when the liability is created, so disallowance can arise if TDS is not deducted at that stage. Where deducted tax is deposited on or before the return-filing due date, the related expenditure is allowable for that year; if deposit is later, allowance shifts to the year of actual payment. Payments to offshore lawyers require examination of chargeability in India and any treaty protection before withholding is determined. A provision later reversed because the amount was not payable is treated as an unascertained liability and is not allowable.
Note: It is a system-generated summary and is for quick reference only.