Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
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