https://www.taxtmi.com/caselaws?id=393798 The tribunal upheld the disallowance under section 14A but directed the Assessing Officer to recompute it. Disallowance under section 14A cannot be added to book profits for section 115JB. Additional depreciation was allowed. Corporate advertisement expenses were treated as revenue expenditure. ESOP expenses were allowed as revenue expenditure. Corporate guarantee was treated as an international transaction. Interest under sections 234B, 234C, and 234D was mandatory. Penalty proceedings were deemed premature. Education cess issue was sent back for verification. TDS provisions for year-end provisions were upheld. Addition for CENVAT credit was deleted. Provision for leave salary was allowed. Head office expenses were not allocated to export-oriented units. Depreciation on goodwill was allowed. Sale of certified emission reductions was treated as capital receipts. Reversal of provision for pension liability was treated as income. ALP of guarantee fees was restricted. Interest subsidy from TUF was treated as capital in nature. en-us Mon, 24 Feb 2020 00:00:00 +0530 Mon, 23 Mar 2020 11:49:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393798 The tribunal upheld the disallowance under section 14A but directed the Assessing Officer to recompute it. Disallowance under section 14A cannot be added to book profits for section 115JB. Additional depreciation was allowed. Corporate advertisement expenses were treated as revenue expenditure. ESOP expenses were allowed as revenue expenditure. Corporate guarantee was treated as an international transaction. Interest under sections 234B, 234C, and 234D was mandatory. Penalty proceedings were deemed premature. Education cess issue was sent back for verification. TDS provisions for year-end provisions were upheld. Addition for CENVAT credit was deleted. Provision for leave salary was allowed. Head office expenses were not allocated to export-oriented units. Depreciation on goodwill was allowed. Sale of certified emission reductions was treated as capital receipts. Reversal of provision for pension liability was treated as income. ALP of guarantee fees was restricted. Interest subsidy from TUF was treated as capital in nature. Case-Laws Income Tax Mon, 24 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393798