Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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HC dismissed the revenue appeal, rejecting the disallowance of depreciation on securities and pension fund contributions. The court found no merit in the revenue's contention under Section 14A and Rule 8D, particularly noting that the shares were held as stock in trade, rendering the provisions inapplicable. The decision aligned with prior judicial precedent from the coordinate bench, effectively upholding the assessee's position on depreciation and pension fund contributions.
HC dismissed the revenue appeal, rejecting the disallowance of depreciation on securities and pension fund contributions. The court found no merit in the revenue's contention under Section 14A and Rule 8D, particularly noting that the shares were held as stock in trade, rendering the provisions inapplicable. The decision aligned with prior judicial precedent from the coordinate bench, effectively upholding the assessee's position on depreciation and pension fund contributions.
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