Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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LIC premium paid to secure annuity for retiring employee-partners under a partnership arrangement was held deductible because it discharged a present contractual obligation already accrued, not a contingent liability. The retirement, age, or service conditions only determined when the annuity became payable; they did not make the premium itself contingent. In the absence of any clause for refund of premium on non-fulfilment of those conditions, Indian Molasses was inapplicable. Applying Bharat Earth Movers and Metal Box, the HC held that an accrued liability remains deductible even if discharged later. The Tribunal's view was rejected, the deduction was allowed, and the appellate authority's order was restored.
LIC premium paid to secure annuity for retiring employee-partners under a partnership arrangement was held deductible because it discharged a present contractual obligation already accrued, not a contingent liability. The retirement, age, or service conditions only determined when the annuity became payable; they did not make the premium itself contingent. In the absence of any clause for refund of premium on non-fulfilment of those conditions, Indian Molasses was inapplicable. Applying Bharat Earth Movers and Metal Box, the HC held that an accrued liability remains deductible even if discharged later. The Tribunal's view was rejected, the deduction was allowed, and the appellate authority's order was restored.
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