Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT ruled that Portfolio Management Service (PMS) fees paid by the appellant to portfolio managers qualify as expenses "wholly and exclusively incurred in connection with the business" and are therefore allowable under Section 37 of the Income Tax Act. The Tribunal distinguished this case from Devendra Motilal Kothari, which addressed PMS fees in the context of capital gains calculations. By allowing the assessee's claim under Rule 27 of the ITAT Rules that PMS fees constitute business expenses rather than costs related to capital asset transfers, the Tribunal determined the Revenue's appeal to be infructuous and dismissed it accordingly.
The ITAT ruled that Portfolio Management Service (PMS) fees paid by the appellant to portfolio managers qualify as expenses "wholly and exclusively incurred in connection with the business" and are therefore allowable under Section 37 of the Income Tax Act. The Tribunal distinguished this case from Devendra Motilal Kothari, which addressed PMS fees in the context of capital gains calculations. By allowing the assessee's claim under Rule 27 of the ITAT Rules that PMS fees constitute business expenses rather than costs related to capital asset transfers, the Tribunal determined the Revenue's appeal to be infructuous and dismissed it accordingly.
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