Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
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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