Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Commission paid to a promoter and full-time working director was held not deductible where the assessee failed to show a direct nexus between the payment and services separate from his ordinary duties. The Tribunal found that his day-to-day involvement in marketing and business development fell within his existing role, and that a turnover-linked commission capped in amount was not justified as an independent business outgo when salary and remuneration were already paid for the same work. Board and shareholder approval was not treated as conclusive, and the disallowance was restored.
Commission paid to a promoter and full-time working director was held not deductible where the assessee failed to show a direct nexus between the payment and services separate from his ordinary duties. The Tribunal found that his day-to-day involvement in marketing and business development fell within his existing role, and that a turnover-linked commission capped in amount was not justified as an independent business outgo when salary and remuneration were already paid for the same work. Board and shareholder approval was not treated as conclusive, and the disallowance was restored.
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