Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
AO disallowed professional fees paid to doctors citing lack of evidence regarding their role as consultants, researchers or advisors. CIT(A) deleted disallowance noting assessee provided logbook, agreements, summary sheets, brochures, manuals and research papers. Tribunal upheld CIT(A)'s order. Regarding disallowance u/s 14A for investments, assessee had sufficient funds as evident from bank statement showing share capital proceeds and mutual fund investments. Tribunal upheld CIT(A)'s deletion of disallowance. For administrative expenses disallowed u/s 14A read with Rule 8D, Tribunal opined AO and CIT(A) failed to record dissatisfaction before applying Rule 8D's third component relating to administrative expenses.
AO disallowed professional fees paid to doctors citing lack of evidence regarding their role as consultants, researchers or advisors. CIT(A) deleted disallowance noting assessee provided logbook, agreements, summary sheets, brochures, manuals and research papers. Tribunal upheld CIT(A)'s order. Regarding disallowance u/s 14A for investments, assessee had sufficient funds as evident from bank statement showing share capital proceeds and mutual fund investments. Tribunal upheld CIT(A)'s deletion of disallowance. For administrative expenses disallowed u/s 14A read with Rule 8D, Tribunal opined AO and CIT(A) failed to record dissatisfaction before applying Rule 8D's third component relating to administrative expenses.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4875 
