Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
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ITAT upheld the deletion of the addition relating to a notional foreign-exchange loss on restatement of liabilities and assets, finding the assessee had pleaded and reconciled contract liabilities and applied AS-11 such that the alleged loss was revenue in nature and properly accrued; the CIT(A)'s deletion was affirmed. ITAT also affirmed deletion of the disallowance for interest on a residential property, accepting its inclusion in the relevant block of assets. The Tribunal partly sustained the Revenue on directors' foreign-travel expenses, imposing an additional disallowance of Rs.2,00,000 above the disallowed Rs.51,20,000. The section 14A read with Rule 8D addition was deleted for want of AO's satisfaction and proof of nexus.
ITAT upheld the deletion of the addition relating to a notional foreign-exchange loss on restatement of liabilities and assets, finding the assessee had pleaded and reconciled contract liabilities and applied AS-11 such that the alleged loss was revenue in nature and properly accrued; the CIT(A)'s deletion was affirmed. ITAT also affirmed deletion of the disallowance for interest on a residential property, accepting its inclusion in the relevant block of assets. The Tribunal partly sustained the Revenue on directors' foreign-travel expenses, imposing an additional disallowance of Rs.2,00,000 above the disallowed Rs.51,20,000. The section 14A read with Rule 8D addition was deleted for want of AO's satisfaction and proof of nexus.
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