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The Appellate Tribunal addressed several issues in the case. Firstly, the disallowance of provision for a customer loyalty program was allowed as the method used by the assessee was deemed scientific. Secondly, the disallowance u/s 14A r.w.r. 8D was set aside due to lack of recorded satisfaction by the AO. Thirdly, TDS u/s 195 was not required for professional services rendered abroad for US operations in the relevant assessment year. Fourthly, the issue of loss on closure of a boutique in the United States was remitted back to the AO for verification. Fifthly, the deduction u/s. 80IC for common expenses allocation was disallowed. Lastly, the deduction u/s. 80IC on allocation of expenditure on a trademark was remitted back to the AO for re-adjudication. Additionally, marked to market loss and excess depreciation claimed on UPS were allowed in favor of the assessee.
The Appellate Tribunal addressed several issues in the case. Firstly, the disallowance of provision for a customer loyalty program was allowed as the method used by the assessee was deemed scientific. Secondly, the disallowance u/s 14A r.w.r. 8D was set aside due to lack of recorded satisfaction by the AO. Thirdly, TDS u/s 195 was not required for professional services rendered abroad for US operations in the relevant assessment year. Fourthly, the issue of loss on closure of a boutique in the United States was remitted back to the AO for verification. Fifthly, the deduction u/s. 80IC for common expenses allocation was disallowed. Lastly, the deduction u/s. 80IC on allocation of expenditure on a trademark was remitted back to the AO for re-adjudication. Additionally, marked to market loss and excess depreciation claimed on UPS were allowed in favor of the assessee.
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