Commission expenditure linked to pharmaceutical marketing income qualifies as business deduction when recipient identity, genuineness and business pur...
Country of Origin Certificates and declared transaction value supported preferential customs exemption where authenticity and invoice prices remained ...
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Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed.
Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed.
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