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Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Depreciation on franchise rights was allowed on the full actual cost of the intangible asset, because the franchise licence was acquired when the agreement was executed and annual instalments did not limit the asset's cost; any later adjustment would affect subsequent years. Cash payments for daily allowances were disallowed under section 40A(3) because the relevant test is the actual payment to a person in a day, and no Rule 6DD exception was proved. Business research and routed remuneration claims failed for want of proof of actual services and business nexus, while the ad hoc percentage disallowance of web support expenses was deleted for lack of evidentiary basis. Security expenses were allowed on commercial expediency, and several reimbursement, TDS credit and brought-forward loss issues were remanded for verification.
Depreciation on franchise rights was allowed on the full actual cost of the intangible asset, because the franchise licence was acquired when the agreement was executed and annual instalments did not limit the asset's cost; any later adjustment would affect subsequent years. Cash payments for daily allowances were disallowed under section 40A(3) because the relevant test is the actual payment to a person in a day, and no Rule 6DD exception was proved. Business research and routed remuneration claims failed for want of proof of actual services and business nexus, while the ad hoc percentage disallowance of web support expenses was deleted for lack of evidentiary basis. Security expenses were allowed on commercial expediency, and several reimbursement, TDS credit and brought-forward loss issues were remanded for verification.
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