Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
Deduction under section 10AA was denied where the assessee's own Form 56F and audit report showed nil export proceeds in convertible foreign exchange, and supplies to DTA or another SEZ were treated as non-qualifying absent proof of export out of India. Employees' PF and ESI contribution was disallowed because payment was made even beyond the EPFO grace period. Sundry balances written off failed for lack of supporting evidence. Bad debts written off were allowed once the amounts were recorded as irrecoverable in the accounts under TRF Ltd. Adjustment of patent-related liability against an investment was held not to attract section 41(1) because it was a capital asset transaction, not a trading liability. The section 10AA claim for AY 2018-19 was remanded for fresh verification of revised Form 56F.
Deduction under section 10AA was denied where the assessee's own Form 56F and audit report showed nil export proceeds in convertible foreign exchange, and supplies to DTA or another SEZ were treated as non-qualifying absent proof of export out of India. Employees' PF and ESI contribution was disallowed because payment was made even beyond the EPFO grace period. Sundry balances written off failed for lack of supporting evidence. Bad debts written off were allowed once the amounts were recorded as irrecoverable in the accounts under TRF Ltd. Adjustment of patent-related liability against an investment was held not to attract section 41(1) because it was a capital asset transaction, not a trading liability. The section 10AA claim for AY 2018-19 was remanded for fresh verification of revised Form 56F.
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