Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
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