Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
ITAT held that the foreign subsidiary incorporated under UAE law, notwithstanding 100% shareholding by the assessee, cannot be treated as the assessee's proprietorship and its income cannot be taxed as proprietary concern; the Tribunal consistently decided this issue in favour of the assessee. The Tribunal also upheld that electric fittings and installations constitute part of plant and machinery and allowed depreciation at 15% accordingly. Further, payments made to settle a patent infringement dispute were characterised as compensatory commercial expediency and not a penalty or expenditure for a purpose prohibited by law; the disallowance under s.37(1) was deleted and the assessee's related grounds were allowed.
ITAT held that the foreign subsidiary incorporated under UAE law, notwithstanding 100% shareholding by the assessee, cannot be treated as the assessee's proprietorship and its income cannot be taxed as proprietary concern; the Tribunal consistently decided this issue in favour of the assessee. The Tribunal also upheld that electric fittings and installations constitute part of plant and machinery and allowed depreciation at 15% accordingly. Further, payments made to settle a patent infringement dispute were characterised as compensatory commercial expediency and not a penalty or expenditure for a purpose prohibited by law; the disallowance under s.37(1) was deleted and the assessee's related grounds were allowed.
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