Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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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