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Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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