https://www.taxtmi.com/caselaws?id=219046 The article discusses several income-tax issues: for deduction under section 36(1)(viia), the relevant credit balance is the opening balance brought forward on 1 April; payments to Visa International and Master Card International were analysed under section 40(a)(i) with Article 26(3) of the India-US DTAA; forward exchange contract losses were examined on the basis of whether the liability had crystallised; guest house expenditure and section 44C disallowance were considered in light of prior year views; and VRS expenditure was treated as revenue rather than capital. The discussion emphasises consistency with earlier decisions, treaty non-discrimination, and the accrued-versus-contingent liability distinction. en-us Fri, 20 Jan 2012 00:00:00 +0530 Tue, 04 Dec 2012 00:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219046 The article discusses several income-tax issues: for deduction under section 36(1)(viia), the relevant credit balance is the opening balance brought forward on 1 April; payments to Visa International and Master Card International were analysed under section 40(a)(i) with Article 26(3) of the India-US DTAA; forward exchange contract losses were examined on the basis of whether the liability had crystallised; guest house expenditure and section 44C disallowance were considered in light of prior year views; and VRS expenditure was treated as revenue rather than capital. The discussion emphasises consistency with earlier decisions, treaty non-discrimination, and the accrued-versus-contingent liability distinction. Case-Laws Income Tax Fri, 20 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219046