Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Reimbursement of advertisement and promotion on a cost-to-cost basis was held allowable where the sister concern had already deducted tax on the underlying expenditure and no mark-up or lack of genuineness was shown; section 40(a)(ia) disallowance was deleted. Retainership fee under the joint venture arrangement was accepted as business expenditure, but for AY 2005-06 only proportionate accrual from the implementation date was allowed, with full claims upheld for later years. Reimbursement of joint venture operating expenses, business promotion expenditure, and fuel and telephone costs were also allowed, while short deduction of TDS did not attract section 40(a)(ia). Section 14A disallowance was sustained on a reasonable estimate.
Reimbursement of advertisement and promotion on a cost-to-cost basis was held allowable where the sister concern had already deducted tax on the underlying expenditure and no mark-up or lack of genuineness was shown; section 40(a)(ia) disallowance was deleted. Retainership fee under the joint venture arrangement was accepted as business expenditure, but for AY 2005-06 only proportionate accrual from the implementation date was allowed, with full claims upheld for later years. Reimbursement of joint venture operating expenses, business promotion expenditure, and fuel and telephone costs were also allowed, while short deduction of TDS did not attract section 40(a)(ia). Section 14A disallowance was sustained on a reasonable estimate.
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