Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Business-expenditure deductibility after transfer of a branch undertaking depends on whether retained statutory assets and related expenditure continued to serve the business. The phrase "for the purpose of business" extends to acts incidental to carrying on business, but substantial legal and professional expenses cannot be allowed without complete particulars on their nature, purpose, and connection with business operations. Where those facts have not been examined, the disallowance requires fresh factual verification. The expenditure claim was remitted for de novo assessment, with the disallowance set aside for reconsideration in accordance with law.
Business-expenditure deductibility after transfer of a branch undertaking depends on whether retained statutory assets and related expenditure continued to serve the business. The phrase "for the purpose of business" extends to acts incidental to carrying on business, but substantial legal and professional expenses cannot be allowed without complete particulars on their nature, purpose, and connection with business operations. Where those facts have not been examined, the disallowance requires fresh factual verification. The expenditure claim was remitted for de novo assessment, with the disallowance set aside for reconsideration in accordance with law.
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