S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission charges to overseas agents-Service rendered outside India-Cannot be considered as fees for technical services-Not liable to deduct tax at source-Art, 12-OECD Model convention. [S. 9(1)(vii), 195]
S. 37(1) : Business expenditure-Statutory obligation-Contribution to common good fund-Special assistance fund-Allowable as deduction.
S. 37(1) : Business expenditure-Discount on issue of ESOP-Allowable as deduction.
S. 37(1) : Business expenditure-Interest-Prepayment premium-Corporate debt restructuring-Allowable as deduction.
S. 32 : Depreciation-Plant and machinery-Ponds and reservoirs-Pollution control equipment’s- Aerators Depreciation allowable at 25% as against 100% claimed by the assessee-Approach road, drainage, borewells, reservoirs etc-Depreciation allowable at 10 % as against 25% claimed by the assessee. [ S. 43(3 ) ]
S. 32 : Depreciation-Roads-Improvement and development of State Highways-Entitle was entitled depreciation prescribed to building.
S. 17(2) : Perquisite-Permission for providing COVID treatment-Show cause notice-Revocation of permission was lifted-Order was set aside [S. 15, 17(ii)(b),ITATR, 1962, R. 3A, Art. 226]
S. 11 : Property held for charitable purposes-Construction of building for Government-Commission from Government-Involves carrying on of activity in the nature of trade commerce or business-Denial of exemption is held to be justified. [S. 2(15), 12A]
S. 11 : Property held for charitable purposes-Construction of building for Government-Commission from Government-Involves carrying on of activity in the nature of trade commerce or business-Denial of exemption is held to be justified. [S. 2(15), 12A]
S. 11 : Property held for charitable purposes-Engaged in promotion of rapid and orderly establishment, growth and development of industries in State and provided for industrial infrastructural facilities-Object of general public utility, proviso to section 2(15) was not applicable-Entitle for exemption [S. 2(15, 12AA]