Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
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Deduction u/s 35(2AB) for in-house Research and Development (R&D) expenses was disallowed as the assessee failed to properly explain the basis of claim and reconcile the difference between the amount claimed and the expenditure approved by the Department of Scientific and Industrial Research (DSIR). The matter was remitted to the Assessing Officer to correctly verify the eligible expenditure without considering the DSIR-approved amount. The disallowance of interest expenses u/s 36(1)(iii) was deleted as the assessee had sufficient interest-free funds available from reserves and share premium, contrary to the Assessing Officer's presumption that only interest-bearing funds were utilized towards capital work-in-progress (CWIP). The disallowance of capital loss was upheld as the assessee failed to reconcile the difference in CWIP additions, which cannot be considered an actual capital loss eligible for deduction. The disallowance u/s 40(a)(ia) for commission paid to non-residents was set aside for the Commissioner of Income Tax (Appeals) to examine the merits, considering the assessee's contention that the non-residents rendered services outside India. The disallowance of provision for bad debts was upheld as the deduction u/s 36(1)(vii) requires the bad debt to be written off as.
Deduction u/s 35(2AB) for in-house Research and Development (R&D) expenses was disallowed as the assessee failed to properly explain the basis of claim and reconcile the difference between the amount claimed and the expenditure approved by the Department of Scientific and Industrial Research (DSIR). The matter was remitted to the Assessing Officer to correctly verify the eligible expenditure without considering the DSIR-approved amount. The disallowance of interest expenses u/s 36(1)(iii) was deleted as the assessee had sufficient interest-free funds available from reserves and share premium, contrary to the Assessing Officer's presumption that only interest-bearing funds were utilized towards capital work-in-progress (CWIP). The disallowance of capital loss was upheld as the assessee failed to reconcile the difference in CWIP additions, which cannot be considered an actual capital loss eligible for deduction. The disallowance u/s 40(a)(ia) for commission paid to non-residents was set aside for the Commissioner of Income Tax (Appeals) to examine the merits, considering the assessee's contention that the non-residents rendered services outside India. The disallowance of provision for bad debts was upheld as the deduction u/s 36(1)(vii) requires the bad debt to be written off as.
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