Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Ad hoc disallowance of vehicle depreciation cannot stand without adverse material or a factual basis showing personal use or defective record-keeping; where the assessee asserted log books and audit controls and the Revenue produced no specific rebuttal, the disallowance was treated as arbitrary and deleted. Donations for festivities were held allowable where CBDT circulars covered such payments, and those circulars were binding on the Revenue, so the addition was deleted. For fine and penalty expenditure under section 37(1), the record lacked sufficient factual clarity, and the remand to the Assessing Officer for verification was upheld, leaving that issue open on merits.
Ad hoc disallowance of vehicle depreciation cannot stand without adverse material or a factual basis showing personal use or defective record-keeping; where the assessee asserted log books and audit controls and the Revenue produced no specific rebuttal, the disallowance was treated as arbitrary and deleted. Donations for festivities were held allowable where CBDT circulars covered such payments, and those circulars were binding on the Revenue, so the addition was deleted. For fine and penalty expenditure under section 37(1), the record lacked sufficient factual clarity, and the remand to the Assessing Officer for verification was upheld, leaving that issue open on merits.
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