Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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