Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Whether advertising expenditure is revenue or capital: applying statutory principles and binding precedent, the court rejected estoppel against the statute and held that characterization in books does not override tax law; relying on Supreme Court authority and Gujarat HC precedent, such advertisement outlays are not capitalizable but are revenue expenditures deductible under the Act. Consequence: the assessment treating the expenditure as capital was set aside and the appeal allowing deduction was allowed. - HC
Whether advertising expenditure is revenue or capital: applying statutory principles and binding precedent, the court rejected estoppel against the statute and held that characterization in books does not override tax law; relying on Supreme Court authority and Gujarat HC precedent, such advertisement outlays are not capitalizable but are revenue expenditures deductible under the Act. Consequence: the assessment treating the expenditure as capital was set aside and the appeal allowing deduction was allowed. - HC
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