Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Approved gratuity fund contributions adjusted against earlier excess payments were held not to be unpaid provisions, and the gratuity claim was allowable because the fund was approved. Lease-rental disallowance for non-deduction of tax was sustained for the year under appeal, with corresponding deduction allowed in the subsequent year in line with section 40(a)(ia). Short deduction of tax was also treated as falling within section 40(a)(ia), subject to proportionate restriction. Ind AS transition amount was held to be a statutory MAT adjustment, not prior period expense, and the related addition was deleted. Repairs and maintenance expenditure remained revenue in nature despite book capitalisation, and CSR expenditure could not be added back to book profit absent a specific adjustment under section 115JB.
Approved gratuity fund contributions adjusted against earlier excess payments were held not to be unpaid provisions, and the gratuity claim was allowable because the fund was approved. Lease-rental disallowance for non-deduction of tax was sustained for the year under appeal, with corresponding deduction allowed in the subsequent year in line with section 40(a)(ia). Short deduction of tax was also treated as falling within section 40(a)(ia), subject to proportionate restriction. Ind AS transition amount was held to be a statutory MAT adjustment, not prior period expense, and the related addition was deleted. Repairs and maintenance expenditure remained revenue in nature despite book capitalisation, and CSR expenditure could not be added back to book profit absent a specific adjustment under section 115JB.
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