Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
HC upheld deductions claimed under section 37 for license fee paid to use the goodwill and name "Remfry & Sagar." The court determined that payment for using goodwill cannot be viewed as illegal or prohibited by law. The arrangement linking consideration to firm revenue was merely a basis for computing goodwill usage fees, not a prohibited sharing of legal fees under Bar Council rules. The court emphasized that goodwill represents a legitimate transferable asset, and its monetization through license fees constitutes valid business expenditure. The primary purpose was to derive benefit from an established reputation in legal services, not to circumvent professional regulations or engage in tax avoidance. The expenditure was therefore allowable as a legitimate business deduction.
HC upheld deductions claimed under section 37 for license fee paid to use the goodwill and name "Remfry & Sagar." The court determined that payment for using goodwill cannot be viewed as illegal or prohibited by law. The arrangement linking consideration to firm revenue was merely a basis for computing goodwill usage fees, not a prohibited sharing of legal fees under Bar Council rules. The court emphasized that goodwill represents a legitimate transferable asset, and its monetization through license fees constitutes valid business expenditure. The primary purpose was to derive benefit from an established reputation in legal services, not to circumvent professional regulations or engage in tax avoidance. The expenditure was therefore allowable as a legitimate business deduction.
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