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    <title>2025 (9) TMI 1318 - MADRAS HIGH COURT</title>
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    <description>HC held that VRS payments are revenue expenditure and, since VRS was not disallowed by the AO for the year in question, the point was moot. Advertisement and dealer incentive outlays were accepted as incurred; CIT(A) allowed them, ITAT restricted relief to 10%, and HC declined to disturb ITAT&#039;s factual quantum finding in the absence of definite evidence, answering those substantial questions for the assessee. The discounted net present value of deferred sales-tax transferred for Rs. 5.94 crores was held not to attract s.41(1) as the liability stood discharged, also decided for the assessee. One listed substantial question (fifth) was, however, decided for the revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=778829</link>
      <description>HC held that VRS payments are revenue expenditure and, since VRS was not disallowed by the AO for the year in question, the point was moot. Advertisement and dealer incentive outlays were accepted as incurred; CIT(A) allowed them, ITAT restricted relief to 10%, and HC declined to disturb ITAT&#039;s factual quantum finding in the absence of definite evidence, answering those substantial questions for the assessee. The discounted net present value of deferred sales-tax transferred for Rs. 5.94 crores was held not to attract s.41(1) as the liability stood discharged, also decided for the assessee. One listed substantial question (fifth) was, however, decided for the revenue.</description>
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