S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Amount ceasing to be liability-Necessary details not supplied to AO-Evidence produced for the first time-Matter remanded.[S. 254(1)]
S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Amount ceasing to be liability-Necessary details not supplied to AO-Evidence produced for the first time-Matter remanded.[S. 254(1)]
S. 40A (3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits –Additional evidence-No reasonable cause for admitting additional evidence.[ITATR. 29.]
S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Business expediency-Claim not rebutted-Disallowance quashed.[R. 6DD]
S. 40(b)(v) : Amounts not deductible-Partner-Remuneration-Payments as per partnership deed-Permissible limit-Disallowance is not justified. [S. 15, 192]
S. 40(b)(iv) : Amounts not deductible-Partner-Interest-Interest payment to legal heirs of dead partner-Already subjected to tax deducted at source-Cannot be disallowed on the ground of passing of entry-Remanded. [S. 36(1) (iii), 194A]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Documentation charges-Payment paid by assessee-Shown in return of receipts and taxes paid-Disallowance not warranted.[S. 194C]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Business expenditure-Disallowance-Remuneration to directors-Prior to 01.04.2015-Deduction allowable-Audit fees-addition justified.
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Interest-Royalty-Fes for technical services-Advertisement expenses-Server for advertisement located outside India-No control with assessee over functioning of interface provided-No element of Fee for technical services or Royalties-Not liable to deduct tax at source. [S. 9(1)(vii), 195]
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident –Royalty-Income deemed to accrue or arise in India-Payment towards availing of facilities subject to placements of advertisements-Not for license or right to use-Not Royalty-Not liable to deduction of tax at source. [S.9(1)(vi), 195, 201 (1).
S. 37(1) : Business expenditure-Provision for royalty-Matter remanded-Educational cess-Not allowable as deduction. [S. 40(a)(ia)]