Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Payment made to a labour union for facilitating a mutually acceptable settlement with workers was examined for allowability as business expenditure under s. 37(1) on the test of commercial expediency. Since the taxpayer demonstrated a direct nexus between the payment (made through banking channels) and its business activity of resolving labour issues through dialogue and settlement, the expenditure was held to be incurred wholly and exclusively for the purposes of business. Accordingly, the deduction under s. 37(1) was allowed and the appeal was allowed. - ITAT
Payment made to a labour union for facilitating a mutually acceptable settlement with workers was examined for allowability as business expenditure under s. 37(1) on the test of commercial expediency. Since the taxpayer demonstrated a direct nexus between the payment (made through banking channels) and its business activity of resolving labour issues through dialogue and settlement, the expenditure was held to be incurred wholly and exclusively for the purposes of business. Accordingly, the deduction under s. 37(1) was allowed and the appeal was allowed. - ITAT
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