Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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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.
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