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...
Recurring transfer pricing and TDS disputes were decided largely by following the Tribunal's earlier orders in the assessee's own case. AMP adjustment and alleged short charge to the associated enterprise were not disturbed, advertisement and publicity expenditure was held revenue in nature despite an asserted enduring benefit, payment gateway charges were not disallowed for want of TDS, deferred contract receipts were not taxed as accrued income for the unexpired period, reimbursement of ticketing cost to MMT US was held outside section 195 because it was not taxable in India, and ESOP expenditure was treated as allowable employee compensation. Higher depreciation on computer peripherals was rejected.
Recurring transfer pricing and TDS disputes were decided largely by following the Tribunal's earlier orders in the assessee's own case. AMP adjustment and alleged short charge to the associated enterprise were not disturbed, advertisement and publicity expenditure was held revenue in nature despite an asserted enduring benefit, payment gateway charges were not disallowed for want of TDS, deferred contract receipts were not taxed as accrued income for the unexpired period, reimbursement of ticketing cost to MMT US was held outside section 195 because it was not taxable in India, and ESOP expenditure was treated as allowable employee compensation. Higher depreciation on computer peripherals was rejected.
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