Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
The Delhi High Court upheld the order of the Tribunal on the following issues: 1. Transfer Pricing adjustment on Advertising, Marketing and Promotional (AMP) expenditure was rejected in the absence of evidence establishing an arrangement or concerted action between the Indian entity and its Associated Enterprise. 2. Disallowance u/s 14A was not warranted as there was no exempt income earned in the concerned Assessment Years. 3. Disallowance of brand building expenditure u/s 37 was not justified. As per Section 48 of the Trade Marks Act, the assessee, being a licensee, was entitled to claim such expenditure as business expenditure, although it may have enhanced the brand of the overseas owner. 4. Disallowance based on seized material pertaining to preceding years was not merited in the absence of incriminating material for the concerned Assessment Years, following the Supreme Court's decision in Sinhgad Technical Education Society.
The Delhi High Court upheld the order of the Tribunal on the following issues: 1. Transfer Pricing adjustment on Advertising, Marketing and Promotional (AMP) expenditure was rejected in the absence of evidence establishing an arrangement or concerted action between the Indian entity and its Associated Enterprise. 2. Disallowance u/s 14A was not warranted as there was no exempt income earned in the concerned Assessment Years. 3. Disallowance of brand building expenditure u/s 37 was not justified. As per Section 48 of the Trade Marks Act, the assessee, being a licensee, was entitled to claim such expenditure as business expenditure, although it may have enhanced the brand of the overseas owner. 4. Disallowance based on seized material pertaining to preceding years was not merited in the absence of incriminating material for the concerned Assessment Years, following the Supreme Court's decision in Sinhgad Technical Education Society.
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