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Acquisition-related legal and professional expenditure for...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verification.
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Acquisition-related legal and professional expenditure for extending an undertaking or establishing a new unit falls under the specific preliminary-expense amortisation provision rather than the residuary deduction provision; the Assessing Officer's treatment was sustained. Repairs to leased premises remained partly revenue in nature, while depreciation on business-use premises and office equipment was allowed. Trademark renewal and protection expenditure requires verification of whether it merely maintains existing intellectual-property rights and was remanded. Interest disallowance relating to exempt income was restricted where own funds exceeded investments, but expenditure computed under Rule 8D was required to be added back in book-profit computation. Transfer-pricing adjustments on associated-enterprise loans were deleted, corporate guarantee commission was restricted, and excess managerial remuneration was remanded for verification.
Acquisition-related legal and professional expenditure for extending an undertaking or establishing a new unit falls under the specific preliminary-expense amortisation provision rather than the residuary deduction provision; the Assessing Officer's treatment was sustained. Repairs to leased premises remained partly revenue in nature, while depreciation on business-use premises and office equipment was allowed. Trademark renewal and protection expenditure requires verification of whether it merely maintains existing intellectual-property rights and was remanded. Interest disallowance relating to exempt income was restricted where own funds exceeded investments, but expenditure computed under Rule 8D was required to be added back in book-profit computation. Transfer-pricing adjustments on associated-enterprise loans were deleted, corporate guarantee commission was restricted, and excess managerial remuneration was remanded for verification.
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