Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Disallowance of AMP payments as non-genuine: tribunal accepted appellate authority's finding that vendors were regular, turnover corroborated payments and AO raised no material to rebut genuineness - disallowance deleted. Disallowance of salaries paid via credit-notes: tribunal held on facts that deployment of staff at retailers for product promotion is a legitimate marketing model, credit-notes and payments were substantiated and profits remained healthy - disallowance deleted. Apportionment of AMP between assessee and contract manufacturers claiming 80IC benefits: tribunal found brand, formula and marketing exclusively controlled by assessee and prior assessments accepted ALP - no reallocation warranted. Section 14A/Rule 8D: tribunal restricted disallowance to investments that yielded exempt income, following binding precedents - addition limited accordingly. - ITAT
Disallowance of AMP payments as non-genuine: tribunal accepted appellate authority's finding that vendors were regular, turnover corroborated payments and AO raised no material to rebut genuineness - disallowance deleted. Disallowance of salaries paid via credit-notes: tribunal held on facts that deployment of staff at retailers for product promotion is a legitimate marketing model, credit-notes and payments were substantiated and profits remained healthy - disallowance deleted. Apportionment of AMP between assessee and contract manufacturers claiming 80IC benefits: tribunal found brand, formula and marketing exclusively controlled by assessee and prior assessments accepted ALP - no reallocation warranted. Section 14A/Rule 8D: tribunal restricted disallowance to investments that yielded exempt income, following binding precedents - addition limited accordingly. - ITAT
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