Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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For deduction claims of eligible industrial units, only expenditure having a direct nexus with that undertaking can be reduced from profits; common R&D costs cannot be allocated to the units absent proof that they relate to those units. The Court accepted the Tribunal's factual finding that the R&D projects were unrelated to the products manufactured by the deduction-claiming units, were future-oriented and uncertain, and were not shown by the Assessing Officer to pertain to those units. In the absence of nexus, the allocation-based disallowance was unwarranted, no substantial question of law arose, and the Revenue's challenge was rejected.
For deduction claims of eligible industrial units, only expenditure having a direct nexus with that undertaking can be reduced from profits; common R&D costs cannot be allocated to the units absent proof that they relate to those units. The Court accepted the Tribunal's factual finding that the R&D projects were unrelated to the products manufactured by the deduction-claiming units, were future-oriented and uncertain, and were not shown by the Assessing Officer to pertain to those units. In the absence of nexus, the allocation-based disallowance was unwarranted, no substantial question of law arose, and the Revenue's challenge was rejected.
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