Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
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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