Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
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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