International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
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