Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
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Foreign withholding tax eligible for double-taxation relief under sections 90 or 91 cannot be deducted as business expenditure merely because nil Indian tax liability prevents use of the credit. Explanation 1 to section 40(a)(ii) applies based on eligibility for relief, not actual allowance or utilisation; the claimed deduction was therefore rejected. An additional legal claim for that deduction, raised before the first appellate authority, required examination on merits where the return and Form 67 contained the relevant material. Rule 46A did not justify threshold rejection, although the claim ultimately failed.
Foreign withholding tax eligible for double-taxation relief under sections 90 or 91 cannot be deducted as business expenditure merely because nil Indian tax liability prevents use of the credit. Explanation 1 to section 40(a)(ii) applies based on eligibility for relief, not actual allowance or utilisation; the claimed deduction was therefore rejected. An additional legal claim for that deduction, raised before the first appellate authority, required examination on merits where the return and Form 67 contained the relevant material. Rule 46A did not justify threshold rejection, although the claim ultimately failed.
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