Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
ESOP expenditure was held allowable as a deduction under section 37(1) because the jurisdictional Karnataka High Court had already decided the issue in favour of the assessee and upheld deletion of the disallowance in the assessee's own case. Mere pendency of a similar issue before the Supreme Court in another matter did not dilute the binding effect of that High Court ruling. Applying the jurisdictional precedent, the Tribunal rejected the Revenue's challenge and sustained the deletion of the ESOP disallowance.
ESOP expenditure was held allowable as a deduction under section 37(1) because the jurisdictional Karnataka High Court had already decided the issue in favour of the assessee and upheld deletion of the disallowance in the assessee's own case. Mere pendency of a similar issue before the Supreme Court in another matter did not dilute the binding effect of that High Court ruling. Applying the jurisdictional precedent, the Tribunal rejected the Revenue's challenge and sustained the deletion of the ESOP disallowance.
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