International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Section 40(a)(ia) disallowance applies only to expenditure actually claimed as a deduction in computing business income; where TDS-defaulted amounts remained capitalised in work-in-progress and were not charged to the profit and loss account, no current-year disallowance was warranted. Even under the percentage completion method, the decisive question was whether the expense had entered the year's computation, and the balance had to be adjusted in work-in-progress to avoid later deduction without compliance. The audit report could not override the actual accounting treatment. The Tribunal therefore upheld the CIT(A)'s limited verification approach and dismissed the Revenue's appeal.
Section 40(a)(ia) disallowance applies only to expenditure actually claimed as a deduction in computing business income; where TDS-defaulted amounts remained capitalised in work-in-progress and were not charged to the profit and loss account, no current-year disallowance was warranted. Even under the percentage completion method, the decisive question was whether the expense had entered the year's computation, and the balance had to be adjusted in work-in-progress to avoid later deduction without compliance. The audit report could not override the actual accounting treatment. The Tribunal therefore upheld the CIT(A)'s limited verification approach and dismissed the Revenue's appeal.
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