Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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The Tribunal upheld deletion of the section 14A disallowance, holding that interest-free surplus funds covered the investments and that administrative disallowance could not exceed the consistent 2% approach followed in earlier years. It also sustained treatment of professional fees as revenue expenditure, finding they supported existing business expansion without creating a capital asset or enduring advantage. The bad debt write-off was allowed because post-amendment section 36(1)(vii) requires only an actual write-off in the accounts. Payment for public relation services was held deductible on proof of commercial expediency and receipt of services. Deduction under section 80IA for the captive incinerator facility was sustained on market-value basis and consistency. Interest under section 234A was left for factual verification of timely filing.
The Tribunal upheld deletion of the section 14A disallowance, holding that interest-free surplus funds covered the investments and that administrative disallowance could not exceed the consistent 2% approach followed in earlier years. It also sustained treatment of professional fees as revenue expenditure, finding they supported existing business expansion without creating a capital asset or enduring advantage. The bad debt write-off was allowed because post-amendment section 36(1)(vii) requires only an actual write-off in the accounts. Payment for public relation services was held deductible on proof of commercial expediency and receipt of services. Deduction under section 80IA for the captive incinerator facility was sustained on market-value basis and consistency. Interest under section 234A was left for factual verification of timely filing.
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