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...
Assessee successfully contested disallowances: the Tribunal found proportionate interest disallowance under section 36(1)(iii) unjustified because loans and advances were funded from the assessee's own interest-free funds and repayments demonstrated genuineness; reimbursement payments for staff training to Mahindra & Mahindra Ltd. did not attract TDS under section 194C and so section 40(a)(ia) disallowance was deleted; discrepancies between income in the return and Form 26AS were attributable to legitimate business adjustments and the assessee explained RTO reimbursements, so additions and the section 40A(3) cash expenditure disallowance were deleted. The appeal was allowed in entirety.
Assessee successfully contested disallowances: the Tribunal found proportionate interest disallowance under section 36(1)(iii) unjustified because loans and advances were funded from the assessee's own interest-free funds and repayments demonstrated genuineness; reimbursement payments for staff training to Mahindra & Mahindra Ltd. did not attract TDS under section 194C and so section 40(a)(ia) disallowance was deleted; discrepancies between income in the return and Form 26AS were attributable to legitimate business adjustments and the assessee explained RTO reimbursements, so additions and the section 40A(3) cash expenditure disallowance were deleted. The appeal was allowed in entirety.
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