Misdeclaration of quantity rejected where supplier evidence established counting errors, so reassessment, confiscation and redemption fine were set as...
Admissibility of electronic evidence controls valuation and penalty exposure; non compliant e records and statements nullify revaluation and penalties...
Deductibility of software licence fees was treated as revenue expenditure because licences were limited-term, conferred no enduring benefit, and available material established revenue treatment; disallowance deleted. Depreciation on intangible assets acquired under business transfer agreements was allowed because assets were not recorded or depreciated by transferor, so aggregate deduction did not arise and the sixth proviso to section 32(1) did not apply; AO directed to allow depreciation. Claim to deduct foreign taxes as business expenses under section 37(1) was restored to the AO for factual verification including foreign tax credit and section 40(a)(ii) considerations. Weighted deduction under section 35(2AB) for in house R&D was allowed; alternatively expenditure directed to be considered under section 35(1)(i).
Deductibility of software licence fees was treated as revenue expenditure because licences were limited-term, conferred no enduring benefit, and available material established revenue treatment; disallowance deleted. Depreciation on intangible assets acquired under business transfer agreements was allowed because assets were not recorded or depreciated by transferor, so aggregate deduction did not arise and the sixth proviso to section 32(1) did not apply; AO directed to allow depreciation. Claim to deduct foreign taxes as business expenses under section 37(1) was restored to the AO for factual verification including foreign tax credit and section 40(a)(ii) considerations. Weighted deduction under section 35(2AB) for in house R&D was allowed; alternatively expenditure directed to be considered under section 35(1)(i).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
