Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
Goodwill amortisation was held to be an extraordinary/non operating expense for PLI computation under the TNMM and must be treated as non operating with corresponding adjustment to the PLI when computing ALP; the matter was remanded to AO/TPO only for verification whether depreciation was claimed and for giving the assessee opportunity of hearing. The Tribunal found the lower authorities misconstrued an earlier direction, directed AO/TPO to adjust PLI accordingly, and held initiation of penalty proceedings as premature and dismissed them.
Goodwill amortisation was held to be an extraordinary/non operating expense for PLI computation under the TNMM and must be treated as non operating with corresponding adjustment to the PLI when computing ALP; the matter was remanded to AO/TPO only for verification whether depreciation was claimed and for giving the assessee opportunity of hearing. The Tribunal found the lower authorities misconstrued an earlier direction, directed AO/TPO to adjust PLI accordingly, and held initiation of penalty proceedings as premature and dismissed them.
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