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...
Software expenditure was held to require a year-specific functional test: software forming part of the profit-making apparatus and enhancing system capacity or functionality was treated as capital expenditure with depreciation allowable, while routine subscription-based software was allowed as revenue expenditure. Section 14A disallowance was confined by applying the presumption that investments were made out of own funds where interest-free funds exceeded investments, and Rule 8D(2)(iii) was restricted to investments that actually yielded exempt income; no MAT addition followed where there was no disallowance under Rule 8D(2)(i). Debenture Redemption Reserve was held to be a provision for a known liability set apart for debenture redemption, not an unascertained reserve, and was excluded from book profit under section 115JB.
Software expenditure was held to require a year-specific functional test: software forming part of the profit-making apparatus and enhancing system capacity or functionality was treated as capital expenditure with depreciation allowable, while routine subscription-based software was allowed as revenue expenditure. Section 14A disallowance was confined by applying the presumption that investments were made out of own funds where interest-free funds exceeded investments, and Rule 8D(2)(iii) was restricted to investments that actually yielded exempt income; no MAT addition followed where there was no disallowance under Rule 8D(2)(i). Debenture Redemption Reserve was held to be a provision for a known liability set apart for debenture redemption, not an unascertained reserve, and was excluded from book profit under section 115JB.
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