Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Deductibility of compensation paid for exchange rate loss was tested by analysing the contract and commercial expediency; the High Court found a contractual compensation clause and accepted genuineness of the payment, concluding the expenditure falls within business expenditure principles and should be allowed. The Tribunal's reversal based solely on absence of an express agreement clause was rejected, and the CIT(A)'s allowance on commercial expediency was restored, resulting in relief to the assessee on the tax disallowance.
Deductibility of compensation paid for exchange rate loss was tested by analysing the contract and commercial expediency; the High Court found a contractual compensation clause and accepted genuineness of the payment, concluding the expenditure falls within business expenditure principles and should be allowed. The Tribunal's reversal based solely on absence of an express agreement clause was rejected, and the CIT(A)'s allowance on commercial expediency was restored, resulting in relief to the assessee on the tax disallowance.
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