Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.
Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.
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