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...
Ad hoc capitalization of advertisement, publicity and sales promotion expenditure was found unsustainable because no tangible basis showed creation of a capital asset or brand-building benefit; the expenditure remained revenue in nature. TDS credit was held to follow the income actually offered to tax under the contract period, so a mismatch between TDS reflected and income assessable in the year could not justify an addition where section 199(3) and Rule 37BA(3)(i) were correctly applied. Interest under section 244A was not taxable on accrual basis because income accrues only when there is an enforceable right to receive it, and the amount had not actually become receivable in the relevant year.
Ad hoc capitalization of advertisement, publicity and sales promotion expenditure was found unsustainable because no tangible basis showed creation of a capital asset or brand-building benefit; the expenditure remained revenue in nature. TDS credit was held to follow the income actually offered to tax under the contract period, so a mismatch between TDS reflected and income assessable in the year could not justify an addition where section 199(3) and Rule 37BA(3)(i) were correctly applied. Interest under section 244A was not taxable on accrual basis because income accrues only when there is an enforceable right to receive it, and the amount had not actually become receivable in the relevant year.
Note: It is a system-generated summary and is for quick reference only.