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...
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.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
