Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
The ITAT Chennai addressed several issues. Firstly, regarding TDS u/s 195/192, it held that payments made to overseas group entities for relocation expenses of secondment employees were not subject to TDS as they were reimbursement of internal business costs, not taxable income. The matter was remitted to the AO for verification. Secondly, non-credit of DDT paid u/s 115O was remitted for verification of the amount paid. Thirdly, DDT liability u/s 115-O for dividends paid to a UK entity was to be decided by lower authorities. Lastly, lease rental payments were allowed as deductible expenses, with depreciation on assets taken on finance lease being part of the disallowance under section 32. The confusion created by the AO was clarified, and the Revenue's appeal on this issue was dismissed.
The ITAT Chennai addressed several issues. Firstly, regarding TDS u/s 195/192, it held that payments made to overseas group entities for relocation expenses of secondment employees were not subject to TDS as they were reimbursement of internal business costs, not taxable income. The matter was remitted to the AO for verification. Secondly, non-credit of DDT paid u/s 115O was remitted for verification of the amount paid. Thirdly, DDT liability u/s 115-O for dividends paid to a UK entity was to be decided by lower authorities. Lastly, lease rental payments were allowed as deductible expenses, with depreciation on assets taken on finance lease being part of the disallowance under section 32. The confusion created by the AO was clarified, and the Revenue's appeal on this issue was dismissed.
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