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...
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Estimation of Profit/Section 40A(2)(b) - JV entered - sub-contracting - AO had formed a view that the assessee JV had suppressed its profit by making excessive payment to TPPL - the section 40A(2)(b) has no application to income aspect of the assessee JV in the facts of the instant case. The AO has not brought any comparable figures to disallow the expenditure, moreover with the structuring of the JV provisions of Section 40A(2)(b) are not attracted in the given facts and circumstances of the instant case. - Additions deleted - AT
Estimation of Profit/Section 40A(2)(b) - JV entered - sub-contracting - AO had formed a view that the assessee JV had suppressed its profit by making excessive payment to TPPL - the section 40A(2)(b) has no application to income aspect of the assessee JV in the facts of the instant case. The AO has not brought any comparable figures to disallow the expenditure, moreover with the structuring of the JV provisions of Section 40A(2)(b) are not attracted in the given facts and circumstances of the instant case. - Additions deleted - AT
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