Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Addition made towards receipt Assignment of Fee - Assessee has withdrawn amount from Escrow account and utilized for its business purpose - Although, there is a timing difference between assessment year 2008-09 and 2009-10, but because there is no change in rate of tax, there is no loss to the Revenue by deferring recognition of income to assessment year 2009-10. It is also a matter of fact that the assessee has not claimed any set-off of loss against said income in the subsequent years. - AO was completely erred in taxing assignment fee for the assessment year 2008-09 - AT
Addition made towards receipt Assignment of Fee - Assessee has withdrawn amount from Escrow account and utilized for its business purpose - Although, there is a timing difference between assessment year 2008-09 and 2009-10, but because there is no change in rate of tax, there is no loss to the Revenue by deferring recognition of income to assessment year 2009-10. It is also a matter of fact that the assessee has not claimed any set-off of loss against said income in the subsequent years. - AO was completely erred in taxing assignment fee for the assessment year 2008-09 - AT
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