https://www.taxtmi.com/caselaws?id=471273 Payments to six non-resident recipients for professional services and reimbursements did not constitute royalty under domestic law or the applicable treaty, so withholding-related disallowance was removed; an unsupported Singapore reimbursement remained disallowed. Related-party payments require evidence of fair market value, legitimate business needs and benefit derived, requiring fresh verification where no comparables or basis supports an ad hoc adjustment. Bad debts written off in the accounts are deductible without proof of actual irrecoverability. Employee club membership fees qualify as business expenditure. Provident fund contributions paid before the return-filing due date are deductible under the stated curative retrospective treatment. Repairs and maintenance expenditure may attract a reasonable estimated disallowance where full verification is unavailable. en-us Wed, 05 Dec 2012 00:00:00 +0530 Thu, 27 Aug 2026 12:44:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471273 Payments to six non-resident recipients for professional services and reimbursements did not constitute royalty under domestic law or the applicable treaty, so withholding-related disallowance was removed; an unsupported Singapore reimbursement remained disallowed. Related-party payments require evidence of fair market value, legitimate business needs and benefit derived, requiring fresh verification where no comparables or basis supports an ad hoc adjustment. Bad debts written off in the accounts are deductible without proof of actual irrecoverability. Employee club membership fees qualify as business expenditure. Provident fund contributions paid before the return-filing due date are deductible under the stated curative retrospective treatment. Repairs and maintenance expenditure may attract a reasonable estimated disallowance where full verification is unavailable. Case-Laws Income Tax Wed, 05 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471273