TaxTMI 
TaxTMI 
2026 (9) TMI 641
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....RUN K. PATEL(3802) for the Appellant(s) No. 1 MR R.K. Patel, LD. SR. Adv With Mr. Darshan R Patel (8486) for the Opponent(s) No. 1 ORAL ORDER (PER : HONOURABLE Mr. JUSTICE BHARGAV D. KARIA) 1. Heard learned Senior Standing Counsel Mr. Varun K. Patel for the appellant-Revenue and learned Senior Advocate Mr. R.K. Patel assisted by learned advocate Mr. Darshan R. Patel for the respondent-....
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....cision is ex-facie perverse because Appellate Tribunal has erred in deleting the addition made on account of the guarantee fee charge of Rs. 10,45,32,855/- by ignoring the ALP determined by using external Comparable Uncontrolled Price (CUP) Method? [B] Whether on the facts and circumstances of the case and in law, the Appellate Tribunal was justified in deleting the addition made on accou....
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....d in deleting the addition of Rs. 8,60,25,625/- made on account of Trademark Registration & Patent Fee considering the same as revenue expense despite of the facts that they are not recurring the nature? [F] Whether on the facts and circumstances of the case and in law, the Appellate Tribunal was justified in deleting the addition of Rs. 39,39,31,000/- made on account of expenses incurred....
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....the assessee has actually received the sum from the partnership firm falling within the purview of section 56 of the Act? [I] Whether on the facts and circumstances of the case and in law, the Appellate Tribunal was justified in excluding the disallowance made under section 14A while computing of Book Profit under Section 115JB ignoring the clause (f) of Explanation-1 to section 115JB(2)?....