Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
DCF valuation adopted for share premium under Rule 11UA cannot be replaced by the NAV method merely because projected results differ from subsequent actual performance. Consistent acceptance of the same premium in earlier years and for identical shares issued to non-residents supports equivalent treatment for resident shareholders. Occupancy certificates do not determine the deductibility of borrowing interest where commercial buildings have been put to use, rental income is assessed as business income, and borrowings funded construction. Advertisement and marketing costs for commercial space remain allowable business expenditure where incurred for commercial exploitation, notwithstanding a subsequently obtained occupancy certificate.
DCF valuation adopted for share premium under Rule 11UA cannot be replaced by the NAV method merely because projected results differ from subsequent actual performance. Consistent acceptance of the same premium in earlier years and for identical shares issued to non-residents supports equivalent treatment for resident shareholders. Occupancy certificates do not determine the deductibility of borrowing interest where commercial buildings have been put to use, rental income is assessed as business income, and borrowings funded construction. Advertisement and marketing costs for commercial space remain allowable business expenditure where incurred for commercial exploitation, notwithstanding a subsequently obtained occupancy certificate.
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