Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
ITAT held that the appellant's pre-operative expenditure is revenue in nature and not required to be capitalised for tax purposes. The Tribunal directed allowance of weighted deduction under s.35(2AB) for DSIR-approved R&D expenses incurred abroad and at Limda (Vadodara). Additions under s.40(a)(i) for failure to deduct TDS on payments to a foreign AE were sustained, the AO having not established reimbursement status. Foreign-exchange reversal credited to P&L was deleted under s.43A. Year-end provisions and an advance write-back were remanded to the AO for factual verification. Expenditure on gifts was allowed. TPO's benchmarking of a corporate guarantee was reduced to 0.5%; other benchmarking issues were remanded.
ITAT held that the appellant's pre-operative expenditure is revenue in nature and not required to be capitalised for tax purposes. The Tribunal directed allowance of weighted deduction under s.35(2AB) for DSIR-approved R&D expenses incurred abroad and at Limda (Vadodara). Additions under s.40(a)(i) for failure to deduct TDS on payments to a foreign AE were sustained, the AO having not established reimbursement status. Foreign-exchange reversal credited to P&L was deleted under s.43A. Year-end provisions and an advance write-back were remanded to the AO for factual verification. Expenditure on gifts was allowed. TPO's benchmarking of a corporate guarantee was reduced to 0.5%; other benchmarking issues were remanded.
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