Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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The ITAT upheld deduction under section 10AA for three SEZ undertakings and for onsite software development profits, and rejected the section 14A disallowance because no exempt income was earned. It also sustained depreciation on goodwill and exclusion of Australian fringe benefit tax from book profit under section 115JB. Foreign tax credit for Japan taxes was allowed, while taxes not eligible for treaty credit were held deductible under section 37(1). The assessee's challenge to allocation of interest cost to section 10AA units failed. Exchange fluctuation was to be split between capital and revenue components, with only the revenue part taxed. Delisting expenses were restored for want of evidence, and prior period expense and foreign tax credit recomputation issues were remanded.
The ITAT upheld deduction under section 10AA for three SEZ undertakings and for onsite software development profits, and rejected the section 14A disallowance because no exempt income was earned. It also sustained depreciation on goodwill and exclusion of Australian fringe benefit tax from book profit under section 115JB. Foreign tax credit for Japan taxes was allowed, while taxes not eligible for treaty credit were held deductible under section 37(1). The assessee's challenge to allocation of interest cost to section 10AA units failed. Exchange fluctuation was to be split between capital and revenue components, with only the revenue part taxed. Delisting expenses were restored for want of evidence, and prior period expense and foreign tax credit recomputation issues were remanded.
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