Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Routine administrative and operational expenses were held allowable where the record contained no specific adverse finding that the expenditure was false or non-genuine. Disallowance based only on minimal business activity or an allegation that the entities were shell concerns was treated as perverse on the facts. The accepted genuineness of statutory and compliance-related expenses also supported the existence of normal operational costs, so the sustained disallowance of salary, rent, travelling, conveyance, telephone and similar business expenses was deleted. Interest under the consequential challenge was left to follow the main result.
Routine administrative and operational expenses were held allowable where the record contained no specific adverse finding that the expenditure was false or non-genuine. Disallowance based only on minimal business activity or an allegation that the entities were shell concerns was treated as perverse on the facts. The accepted genuineness of statutory and compliance-related expenses also supported the existence of normal operational costs, so the sustained disallowance of salary, rent, travelling, conveyance, telephone and similar business expenses was deleted. Interest under the consequential challenge was left to follow the main result.
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