https://www.taxtmi.com/caselaws?id=793884 Additional jurisdictional objections were not accepted where the challenge was raised belatedly under the Income-tax Act's jurisdictional framework, though the additional ground itself was admitted as a pure question of law. Treaty relief for dividend distribution tax under section 115-O was held prima facie available in principle, but factual verification of treaty documents and residence status was required, so the issue was remanded. Provisions for liquidated damages and warranty were treated as deductible only to the extent they reflected accrued, reasonably estimated liabilities, with relief to avoid double taxation on reversals. An isolated section 145A stock adjustment was deleted because inventory valuation must be applied consistently across opening stock, purchases, sales and closing stock. A payment wrongly booked as commission was allowed as genuine business expenditure on the true nature of the transaction. en-us Tue, 16 Jun 2026 00:00:00 +0530 Thu, 25 Jun 2026 08:27:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793884 Additional jurisdictional objections were not accepted where the challenge was raised belatedly under the Income-tax Act's jurisdictional framework, though the additional ground itself was admitted as a pure question of law. Treaty relief for dividend distribution tax under section 115-O was held prima facie available in principle, but factual verification of treaty documents and residence status was required, so the issue was remanded. Provisions for liquidated damages and warranty were treated as deductible only to the extent they reflected accrued, reasonably estimated liabilities, with relief to avoid double taxation on reversals. An isolated section 145A stock adjustment was deleted because inventory valuation must be applied consistently across opening stock, purchases, sales and closing stock. A payment wrongly booked as commission was allowed as genuine business expenditure on the true nature of the transaction. Case-Laws Income Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793884