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...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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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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