Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
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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