Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
ITAT held that deduction for additional employee cost is allowable for three assessment years under the statutory scheme and upheld CIT(A)'s allowance. It deleted interest disallowance under section 14A/Rule 8D because interest-free own funds exceeded exempt investments and Rule 8D's mechanical computation was unsustainable without AO's cogent dissatisfaction. The Tribunal found write back of creditors reflected in profit before tax, disallowing a fresh addition. AJIO marketing outlays were treated as revenue expenditure despite Ind AS capitalisation. Section 80G deductions operate independently of section 37(1) CSR disallowance and were allowed. Foreign tax credit claim filed before assessment completion was remitted for verification and grant by the AO.
ITAT held that deduction for additional employee cost is allowable for three assessment years under the statutory scheme and upheld CIT(A)'s allowance. It deleted interest disallowance under section 14A/Rule 8D because interest-free own funds exceeded exempt investments and Rule 8D's mechanical computation was unsustainable without AO's cogent dissatisfaction. The Tribunal found write back of creditors reflected in profit before tax, disallowing a fresh addition. AJIO marketing outlays were treated as revenue expenditure despite Ind AS capitalisation. Section 80G deductions operate independently of section 37(1) CSR disallowance and were allowed. Foreign tax credit claim filed before assessment completion was remitted for verification and grant by the AO.
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