Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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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