Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Deduction for gratuity actually paid under section 43B was allowed because the assessee substantiated actual payment with audited financial statements, actuarial provision entries, profit and loss account debit, gratuity disclosures, and supporting ledger and salary records. The Tribunal held that the evidentiary record proved payment to the relevant employees and that the disallowance based on alleged absence of proof was factually unsustainable. The deletion of the disallowance was therefore upheld and the claim for deduction was allowed.
Deduction for gratuity actually paid under section 43B was allowed because the assessee substantiated actual payment with audited financial statements, actuarial provision entries, profit and loss account debit, gratuity disclosures, and supporting ledger and salary records. The Tribunal held that the evidentiary record proved payment to the relevant employees and that the disallowance based on alleged absence of proof was factually unsustainable. The deletion of the disallowance was therefore upheld and the claim for deduction was allowed.
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