Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Disallowance of deduction on account of payment to L&T Ltd. for reimbursement of employee related option scheme was rejected as the payments were not doubted by the AO/CIT(A), TDS was deducted, and no contrary evidence was provided. The expenditure incurred on a cost-to-cost basis for deputed employees was held allowable u/s 37(1). Regarding software license fees, the ITAT held that short-term licenses facilitating business operations qualify as revenue expenditure as no new asset was created. Deduction u/s 10A for the STP unit's first year was allowed as the assessee exported computer software in convertible foreign exchange per CBDT Circular 2/2013 and the Karnataka HC ruling. Loss on forward contracts was treated as a regular business loss u/s 43(5) as the assessee was not a forex dealer but an exporter hedging against losses through forward contracts related to export services.
Disallowance of deduction on account of payment to L&T Ltd. for reimbursement of employee related option scheme was rejected as the payments were not doubted by the AO/CIT(A), TDS was deducted, and no contrary evidence was provided. The expenditure incurred on a cost-to-cost basis for deputed employees was held allowable u/s 37(1). Regarding software license fees, the ITAT held that short-term licenses facilitating business operations qualify as revenue expenditure as no new asset was created. Deduction u/s 10A for the STP unit's first year was allowed as the assessee exported computer software in convertible foreign exchange per CBDT Circular 2/2013 and the Karnataka HC ruling. Loss on forward contracts was treated as a regular business loss u/s 43(5) as the assessee was not a forex dealer but an exporter hedging against losses through forward contracts related to export services.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4790
Join Channel
TaxTMI 
