Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
No disallowance under section 14A was sustained where no exempt income arose; the DRP's deletion of the 14A addition was upheld. The DRP's deletion of the 40(a)(ia) TDS disallowance for transmission and uplinking payments to a foreign satellite entity was confirmed, the payer's TDS obligation negated on facts. Software and upgrade costs were held revenue in nature for broadcasting and the related disallowance deleted. The assessee's revised ESOP expense claim was allowed as deductible business expenditure. Multiple entities were excluded from TNMM comparables as functionally dissimilar; the question whether a corporate guarantee constitutes an international transaction was remitted to the AO/TPO for fresh examination.
No disallowance under section 14A was sustained where no exempt income arose; the DRP's deletion of the 14A addition was upheld. The DRP's deletion of the 40(a)(ia) TDS disallowance for transmission and uplinking payments to a foreign satellite entity was confirmed, the payer's TDS obligation negated on facts. Software and upgrade costs were held revenue in nature for broadcasting and the related disallowance deleted. The assessee's revised ESOP expense claim was allowed as deductible business expenditure. Multiple entities were excluded from TNMM comparables as functionally dissimilar; the question whether a corporate guarantee constitutes an international transaction was remitted to the AO/TPO for fresh examination.
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