Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Liquidated damages, underwriting commission and structuring fees were treated as interest for exemption under section 10(23G): liquidated damages were covered by the court's earlier ruling, underwriting commission fell within the Explanation to section 10(23G) as commission for extending a guarantee or enhancing credit, and structuring fees were included within the expanded definition of interest in section 2(28A) as service fee or other charge connected with borrowed money. On deductions, the court held that sections 36(1)(viia)(c) and 36(1)(viii) operate independently, so deduction under one provision cannot be deferred until the other is exhausted; the amendment to section 36(1)(viii) affected only computation. The questions addressed were answered in favour of the assessee.
Liquidated damages, underwriting commission and structuring fees were treated as interest for exemption under section 10(23G): liquidated damages were covered by the court's earlier ruling, underwriting commission fell within the Explanation to section 10(23G) as commission for extending a guarantee or enhancing credit, and structuring fees were included within the expanded definition of interest in section 2(28A) as service fee or other charge connected with borrowed money. On deductions, the court held that sections 36(1)(viia)(c) and 36(1)(viii) operate independently, so deduction under one provision cannot be deferred until the other is exhausted; the amendment to section 36(1)(viii) affected only computation. The questions addressed were answered in favour of the assessee.
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