S.92C:Transfer pricing – Assessee accepted MAP resolution arrived at between competent authorities of India and Japan, issues raised in appeal became infructuous and, thus, same were to be dismissed as withdrawn. [ S.254(1) ]
S.92C:Transfer pricing – Assessee accepted MAP resolution arrived at between competent authorities of India and Japan, issues raised in appeal became infructuous and, thus, same were to be dismissed as withdrawn. [ S.254(1) ]
S. 69 :Unexplained investments – Search and seizure – Bogus purchases – Diary -Contents of a seized document are to be read in toto, and it is not permissible on part of an AO to dissect same and therein summarily accept same in part and reject other part. [ S. 132, 292C ]
S. 45 : Capital gains – Capital receipt – Professional goodwill -Business income -Compensation – Amount received against termination of right – Held to be capital receipt [ S. 2(14), 4, 28(ii(a), 55 ]
S.37(1): Business expenditure – Capital or revenue – DTT subscription to use Deloitte- Brand helped for getting more business- Held to be allowable as business expenditure.
S.37(1): Business expenditure – Club expenses – Expenditure Club expenses incurred by directors of company cannot be denied on ground of personal in nature.
S. 35 : Scientific research – Revenue expenditure incurred on in-house research and development facility, which was duly approved by competent authority . [ S. 35(1)(iv),35(2AB) ]
S.32 : Depreciation- Trade mark – Depreciation cannot be rejected on ground that agreement to acquire trademark was entered into on post dated stamp paper. [ S.147 ,148 ]
S. 14A : Disallowance of expenditure – Exempt income – Disallowance cannot exceed more than exempt income .[ R.8D ]
S.2(24)(iv):Income- The value of benefit or perquisite- Success fee paid by company Tirumala Milk products Pvt Ltd to Barclays Bank could not be treated as perquisites . [ S.48(1) ]
S. 145: Method of accounting -Project Completion Method-Percentage Completion Method- Project completion method is held to be valid- Deletion of addition in respect of advance received from customers is held to be valid . [ S.145(3) ]