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...
Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.
Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.
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TaxTMI 
TaxTMI 
of 4897 
