Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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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