Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
The HC held that premium paid to secure post-retirement annuity was deductible because it discharged an existing contractual obligation, not a contingent liability. The relevant test was whether the liability had already accrued at the time of payment; the fact that the employee's entitlement to receive the annuity depended on retirement, age, or service conditions did not make the premium itself contingent, especially where the policy provided no refund if the contingency failed. The Court applied Bharat Earth Movers and Metal Box, and held Indian Molasses inapplicable. The Tribunal's view was rejected, the assessee's claim was allowed, and the appellate authority's order was restored.
The HC held that premium paid to secure post-retirement annuity was deductible because it discharged an existing contractual obligation, not a contingent liability. The relevant test was whether the liability had already accrued at the time of payment; the fact that the employee's entitlement to receive the annuity depended on retirement, age, or service conditions did not make the premium itself contingent, especially where the policy provided no refund if the contingency failed. The Court applied Bharat Earth Movers and Metal Box, and held Indian Molasses inapplicable. The Tribunal's view was rejected, the assessee's claim was allowed, and the appellate authority's order was restored.
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