https://www.taxtmi.com/caselaws?id=450703 Section 14A disallowance using Rule 8D requires the Assessing Officer to record dissatisfaction with the taxpayer's claim after examining the accounts; absent that step, the disallowance was deleted. Feasibility-study costs relating to entry into a distinct home-improvement business were capital to the attributable extent, resulting in partial relief. Letters of comfort issued for overseas subsidiaries, containing substantive support undertakings and affecting assets or obligations, constituted international transactions; the transfer-pricing adjustment was sustained at the reduced rate. Revenue challenges on research deduction, damaged stock, additional depreciation, sales-promotion trips, royalty waiver and pre-amendment CSR expenditure were rejected, while sundry balances written off were remanded for factual verification. en-us Fri, 01 Mar 2024 00:00:00 +0530 Sat, 01 Aug 2026 13:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450703 Section 14A disallowance using Rule 8D requires the Assessing Officer to record dissatisfaction with the taxpayer's claim after examining the accounts; absent that step, the disallowance was deleted. Feasibility-study costs relating to entry into a distinct home-improvement business were capital to the attributable extent, resulting in partial relief. Letters of comfort issued for overseas subsidiaries, containing substantive support undertakings and affecting assets or obligations, constituted international transactions; the transfer-pricing adjustment was sustained at the reduced rate. Revenue challenges on research deduction, damaged stock, additional depreciation, sales-promotion trips, royalty waiver and pre-amendment CSR expenditure were rejected, while sundry balances written off were remanded for factual verification. Case-Laws Income Tax Fri, 01 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450703