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...
Replacement of dies and moulds was treated as revenue expenditure under current repairs principles, while temporary structural and interior works were accepted as non-enduring and not capital in nature. Weighted deduction for research expenditure on work in progress was allowed on the basis of earlier precedent. Entry tax remained deductible under income tax law despite set-off under sales tax law, and the discount on prepayment of deferred sales tax on an NPV basis was held capital, not income. Amounts paid to foreign entities for ECB-related services were not taxable under the applicable DTAA because the make-available test was not satisfied, so no TDS liability arose. Prior final orders on foreign commission disallowance were followed, and the appeal was dismissed.
Replacement of dies and moulds was treated as revenue expenditure under current repairs principles, while temporary structural and interior works were accepted as non-enduring and not capital in nature. Weighted deduction for research expenditure on work in progress was allowed on the basis of earlier precedent. Entry tax remained deductible under income tax law despite set-off under sales tax law, and the discount on prepayment of deferred sales tax on an NPV basis was held capital, not income. Amounts paid to foreign entities for ECB-related services were not taxable under the applicable DTAA because the make-available test was not satisfied, so no TDS liability arose. Prior final orders on foreign commission disallowance were followed, and the appeal was dismissed.
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