Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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