PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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HC upheld ITAT's dismissal of Revenue's appeals concerning deduction under Section 10A for AYs 2007-08 and 2008-09. It affirmed the CIT(A)'s finding that the AO was not justified in reallocating royalty and management fee expenses, incurred by non-10A units and paid to an overseas group entity, to 10A-eligible captive units based on revenue apportionment. The HC held that such expenses, linked to third-party revenue and services of group entities, could not be attributed to captive 10A units, and that additional allocation of legal and professional expenses was unwarranted. Consequently, disallowance of Section 10A deduction was rightly deleted and Revenue's appeals were dismissed.
HC upheld ITAT's dismissal of Revenue's appeals concerning deduction under Section 10A for AYs 2007-08 and 2008-09. It affirmed the CIT(A)'s finding that the AO was not justified in reallocating royalty and management fee expenses, incurred by non-10A units and paid to an overseas group entity, to 10A-eligible captive units based on revenue apportionment. The HC held that such expenses, linked to third-party revenue and services of group entities, could not be attributed to captive 10A units, and that additional allocation of legal and professional expenses was unwarranted. Consequently, disallowance of Section 10A deduction was rightly deleted and Revenue's appeals were dismissed.
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