Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The Appellate Tribunal addressed various issues in the case. It directed the AO to delete the disallowance of consequential depreciation on unverified expenses and remit the issue of depreciation on unverified purchases for fresh examination. The Tribunal set aside the disallowance of depreciation on goodwill due to the timing of amalgamation and lack of factual examination. The adjustment on a letter of comfort was deleted as it was not considered a guarantee. An additional ground on deduction u/s 10AA was remitted back to the AO. The Tribunal restored the issue of mark to market loss for further examination. ESOP expenses were allowed, and weighted deduction u/s 35(2AB) upheld. Pre-commencement expenses were allowed as revenue expenditure.
The Appellate Tribunal addressed various issues in the case. It directed the AO to delete the disallowance of consequential depreciation on unverified expenses and remit the issue of depreciation on unverified purchases for fresh examination. The Tribunal set aside the disallowance of depreciation on goodwill due to the timing of amalgamation and lack of factual examination. The adjustment on a letter of comfort was deleted as it was not considered a guarantee. An additional ground on deduction u/s 10AA was remitted back to the AO. The Tribunal restored the issue of mark to market loss for further examination. ESOP expenses were allowed, and weighted deduction u/s 35(2AB) upheld. Pre-commencement expenses were allowed as revenue expenditure.
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