Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Allowability of business expenditure: the tribunal applied its prior assessment-year finding on identical facts that power and fuel costs from a captive power plant were genuine business expenses utilised for manufacturing, and therefore upheld deletion of their disallowance against the assessee. Disallowance under Rule 8D: the tribunal reiterated that disallowance calculated under the rule cannot exceed the amount of exempt income for the year, rejected reliance on an administrative circular to enlarge the disallowance, and sustained the CIT(A)'s restriction to exempt income. Appeals allowed for the assessee; revenue appeals dismissed.
Allowability of business expenditure: the tribunal applied its prior assessment-year finding on identical facts that power and fuel costs from a captive power plant were genuine business expenses utilised for manufacturing, and therefore upheld deletion of their disallowance against the assessee. Disallowance under Rule 8D: the tribunal reiterated that disallowance calculated under the rule cannot exceed the amount of exempt income for the year, rejected reliance on an administrative circular to enlarge the disallowance, and sustained the CIT(A)'s restriction to exempt income. Appeals allowed for the assessee; revenue appeals dismissed.
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