Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
ITAT dismissed Revenue's appeal regarding three key issues: public relations expenses, TDS under s.195, and product registration costs. The Tribunal criticized the Assessing Officer's disregard of precedential principles by maintaining previous approaches despite contrary higher judicial rulings. On public relations expenses, ITAT found no justification to deviate from prior favorable rulings. Regarding TDS under s.40(a)(i), payments to Malaysian entity BASC for finance and HR services were held permissible. Product registration expenditure was deemed revenue rather than capital in nature, despite being one-time costs. In cross-objection concerning Dividend Distribution Tax, ITAT followed Special Bench precedent favoring Revenue's position, upholding DDT liability on declared dividends.
ITAT dismissed Revenue's appeal regarding three key issues: public relations expenses, TDS under s.195, and product registration costs. The Tribunal criticized the Assessing Officer's disregard of precedential principles by maintaining previous approaches despite contrary higher judicial rulings. On public relations expenses, ITAT found no justification to deviate from prior favorable rulings. Regarding TDS under s.40(a)(i), payments to Malaysian entity BASC for finance and HR services were held permissible. Product registration expenditure was deemed revenue rather than capital in nature, despite being one-time costs. In cross-objection concerning Dividend Distribution Tax, ITAT followed Special Bench precedent favoring Revenue's position, upholding DDT liability on declared dividends.
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