Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Whether waiver of non-convertible debentures constituted taxable revenue receipt under s.28(iv) or required inclusion under s.41(1): relying on SC precedent that s.28(iv) does not apply to monetary receipts and on record showing the instrument was borrowing with no interest charged to P&L, the waiver is not exigible under s.28(iv) or s.41(1); addition of Rs.75 lakh is deleted. Whether carried forward business losses and unabsorbed depreciation were allowable: return schedules (CFL and UD) substantiate claimed carryforwards and AO/CIT(A) offered no valid rebuttal, so carryforward losses and unabsorbed depreciation must be allowed. - ITAT
Whether waiver of non-convertible debentures constituted taxable revenue receipt under s.28(iv) or required inclusion under s.41(1): relying on SC precedent that s.28(iv) does not apply to monetary receipts and on record showing the instrument was borrowing with no interest charged to P&L, the waiver is not exigible under s.28(iv) or s.41(1); addition of Rs.75 lakh is deleted. Whether carried forward business losses and unabsorbed depreciation were allowable: return schedules (CFL and UD) substantiate claimed carryforwards and AO/CIT(A) offered no valid rebuttal, so carryforward losses and unabsorbed depreciation must be allowed. - ITAT
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