S. 40(a)(ia) : Amounts not deductible-Deduction at source-Additional evidence-NBFC had taken into account interest paid by the assessee while computing the income-Matter remanded to the file of the Assessing Officer. [Form No 26A]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Additional evidence-NBFC had taken into account interest paid by the assessee while computing the income-Matter remanded to the file of the Assessing Officer. [Form No 26A]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Contractors/sub-contractors-Obtained PAN of transporters-Mere violation of provisions of s. 194C(7) would not attract disallowance. [S. 194C(6), 194C(7), R. 31A(4)(vi)]
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Payment of licence fee to holding company-Assessee submitted Certificate from Chartered Accountant and return and computation of income of payee which Showed that payee had disclosed payment in its return and paid taxes thereon-Held, as per Indo-Israel DTAA Income in question not chargeable to tax in India in hands of Non-Resident-No disallowance can be made-DTAA-India-Israel.[S. 201]
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Fes for technical services-Reimbursement of expenses made by assessee to its parent company for salary paid to expatriate employees, was in nature of salary cost and was subjected to TDS under section 192, such reimbursement could not be treated as FTS-DTAA-India-Japan [S. 9(1)(vii),192,195, Art. 12]
S. 37(1) : Business expenditure-Autorised capital-Depreciation cannot be claimed on expenditure incurred towards increase in authorized share capital.[S. 32]
S. 37(1) : Business expenditure-Capital or revenue-Expenditure incurred on ice boxes being made for acquiring or bringing into existence an asset for enduring benefit of business was of capital nature.
S. 37(1) : Business expenditure-Explanation 2, disallowing CSR expenditure is not retrospective in nature.
S. 37(1) : Business expenditure-Non-compete fee being a capital expenditure resulting in enduring benefit cannot be allowed as revenue expenditure.
S. 37(1): Business expenditure-Income from undisclosed sources-Bogus purchases-Expenditure on commission paid-Allowable as deduction. [S. 133(6), Prohibition of Benami property Transactions Act, 1988, S. 24]
S. 37(1) : Business expenditure-Bogus Purchases-Information received from investigation wing Entire bogus purchase cannot be added-Addition restricted to 12.5% of alleged bogus purchases-Insurance premium of director paid by Company-Not incurred wholly and exclusively for the purpose of business-Not allowable as deduction. [S. 133(6)]