Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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).
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