Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Club membership and subscription expenditure is deductible where its business purpose and nexus are established; an ad hoc disallowance requires identification of particular personal or non-business payments, resulting in deletion of the club-expense disallowance. Where own funds exceed exempt-income investments and borrowings serve specified business purposes, investments are presumed funded from own funds, eliminating interest disallowance under section 14A. Administrative disallowance must have a rational nexus to, and cannot exceed, exempt income. Internal handover, capitalisation and deployment records can establish that machinery was put to use, supporting depreciation and additional depreciation. Electrical installations integral to manufacturing machinery qualify as plant and machinery for additional depreciation. Both appeals were partly allowed.
Club membership and subscription expenditure is deductible where its business purpose and nexus are established; an ad hoc disallowance requires identification of particular personal or non-business payments, resulting in deletion of the club-expense disallowance. Where own funds exceed exempt-income investments and borrowings serve specified business purposes, investments are presumed funded from own funds, eliminating interest disallowance under section 14A. Administrative disallowance must have a rational nexus to, and cannot exceed, exempt income. Internal handover, capitalisation and deployment records can establish that machinery was put to use, supporting depreciation and additional depreciation. Electrical installations integral to manufacturing machinery qualify as plant and machinery for additional depreciation. Both appeals were partly allowed.
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