https://www.taxtmi.com/caselaws?id=433510 Payments to Malaysian and Bangladeshi entities for incorporation-related and similar services were held not chargeable to tax in India under the applicable DTAAs, as no permanent establishment or taxable royalty/fees for technical services was shown; accordingly, no tax was deductible under section 195 and the section 40(a)(i) disallowances were deleted. Expenditure connected with the proposed IPO was treated as preliminary business-expansion expenditure allowable under section 35D, so the disallowance was removed. ESOP-related expense was also held deductible because the debit reflected a real employee-cost claim supported by accounting treatment, and the disallowance was deleted. The write-off of Swachh Bharat Cess receivable was disallowed because actual payment during the year was not proved under section 43B(a). en-us Wed, 18 Jan 2023 00:00:00 +0530 Wed, 01 Feb 2023 08:56:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433510 Payments to Malaysian and Bangladeshi entities for incorporation-related and similar services were held not chargeable to tax in India under the applicable DTAAs, as no permanent establishment or taxable royalty/fees for technical services was shown; accordingly, no tax was deductible under section 195 and the section 40(a)(i) disallowances were deleted. Expenditure connected with the proposed IPO was treated as preliminary business-expansion expenditure allowable under section 35D, so the disallowance was removed. ESOP-related expense was also held deductible because the debit reflected a real employee-cost claim supported by accounting treatment, and the disallowance was deleted. The write-off of Swachh Bharat Cess receivable was disallowed because actual payment during the year was not proved under section 43B(a). Case-Laws Income Tax Wed, 18 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433510