Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
Assessees treatment of project selling costs under the percentage completion method conformed with ICAI guidance; advertising, promotion and commission expenses were allowable as revenue expenditure since revenue recognition threshold was not met. Interest on debentures financing the project must be capitalized; AO directed to disallow interest expense claimed without nexus to other uses. Debenture issue expenditure held allowable as borrowing cost. Notional interest on interest-free advances to related parties to be recalculated using assessees cost of capital and cannot increase claimed interest; AO to restrict adjustment to actual claimed interest. Section 14A adjustment partly allowed; TDS disallowance deleted due to excess timely deposit and AOs reverse calculation rejected.
Assessees treatment of project selling costs under the percentage completion method conformed with ICAI guidance; advertising, promotion and commission expenses were allowable as revenue expenditure since revenue recognition threshold was not met. Interest on debentures financing the project must be capitalized; AO directed to disallow interest expense claimed without nexus to other uses. Debenture issue expenditure held allowable as borrowing cost. Notional interest on interest-free advances to related parties to be recalculated using assessees cost of capital and cannot increase claimed interest; AO to restrict adjustment to actual claimed interest. Section 14A adjustment partly allowed; TDS disallowance deleted due to excess timely deposit and AOs reverse calculation rejected.
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