Electronic evidence and search statements in tax assessments require authenticity review and corroboration, while procedural manuals lack statutory fo...
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
Depreciation claim disallowance u/s 40(a)(i) for failure to deduct TDS on capitalized software payments is disallowed, following coordinate bench decision. Addition u/s 28(iv) for assets received free of cost from AEs for testing purposes is rejected, as assets are temporary, returned/destroyed after testing, pricing agreed under MAP embeds indirect benefits, and billing is cost-plus basis, precluding separate addition u/s 28(iv). Assessee's grounds allowed, revenue's appeal dismissed.
Depreciation claim disallowance u/s 40(a)(i) for failure to deduct TDS on capitalized software payments is disallowed, following coordinate bench decision. Addition u/s 28(iv) for assets received free of cost from AEs for testing purposes is rejected, as assets are temporary, returned/destroyed after testing, pricing agreed under MAP embeds indirect benefits, and billing is cost-plus basis, precluding separate addition u/s 28(iv). Assessee's grounds allowed, revenue's appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
