Time Relevance of Expense: commission deductible when incurred; restructuring transfers, lease obligations upheld; unenforceable sale agreement bars l...
Abuse of dominant position allegations against an exchange found not prima facie; regulator reliance on sectoral expertise upheld and no investigation...
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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