Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Interest paid under s.201(1A) for delayed TDS remittance was held not compensatory and hence not deductible as business expenditure under s.37(1), following binding precedent; the disallowance was sustained. Payments to a foreign expert were held to exhibit employer-employee attributes; GST treatment was irrelevant, and the amounts were treated as salary requiring TDS under s.192, so disallowance under s.40(a)(i) for non-deduction was upheld. Disallowance of head-office staff reimbursements under s.44DA lacked a clear adjudication and was remitted to the AO for fresh decision with opportunity of hearing. Bank/performance guarantee charges were not "commission or brokerage" absent a principal-agent relationship, so disallowance under s.40(a) was deleted. Challenge to mere initiation of penalty under s.270A was held non-maintainable. - ITAT
Interest paid under s.201(1A) for delayed TDS remittance was held not compensatory and hence not deductible as business expenditure under s.37(1), following binding precedent; the disallowance was sustained. Payments to a foreign expert were held to exhibit employer-employee attributes; GST treatment was irrelevant, and the amounts were treated as salary requiring TDS under s.192, so disallowance under s.40(a)(i) for non-deduction was upheld. Disallowance of head-office staff reimbursements under s.44DA lacked a clear adjudication and was remitted to the AO for fresh decision with opportunity of hearing. Bank/performance guarantee charges were not "commission or brokerage" absent a principal-agent relationship, so disallowance under s.40(a) was deleted. Challenge to mere initiation of penalty under s.270A was held non-maintainable. - ITAT
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