Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
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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