S. 69C : Unexplained expenditure-Failure to explain the source-Justified in confirming the disallowance.
S. 69C : Unexplained expenditure-Failure to explain the source-Justified in confirming the disallowance.
S. 68 : Cash credits-Share application money-Shell companies-Share holders could not explain their source-Addition is held to be justified.
S. 48 : Capital gains-Computation-Full value of consideration-Retention of money in Escrow account-Possession was handed over-Amount of money in Escrow account has to be considered while computing the capital gain for the purpose of full consideration. [S. 45]
S. 43B : Deductions on actual payment-Tax paid under Kerala Agricultural Income-tax Act-Not allowable as deduction. [S. 10(1), 37(1), Kerala Agricultural Income-tax Act, 1991]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Payment of freight and carriage charges for previous year 2006-07 (1-4-2006 to 31-3-2007)-Disallowance is held to be not valid-Commission payment disallowance is held to be justified. [S. 194C]
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 ) ]