SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
