S. 40(a)(ia) : Amounts not deductible-Deduction at source-Payment of legal professional fees-Additional evidence is filed before the ITAT-Matter remanded. [S.9(1)(vii)]
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Payment of legal professional fees-Additional evidence is filed before the ITAT-Matter remanded. [S.9(1)(vii)]
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Installation and testing service-Fees for technical services-Not liable to tax in India-Not liable to deduct tax at source.[S.9(1)(vii)(b), 195]
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Fes for technical services-Legal and consultancy services for registration of product in foreign country-Not fees for technical services-Not taxable in India-Not liable to deduct tax at source-DTAA-India-USA.[S.9(1)(vii),195 Art.12]
S. 37(1) : Business expenditure-Foreign exchange fluctuation losses-Hedging-Foreign exchange risks in respect of exports and imports-Loss is not speculative-Allowable as business loss.[S.28(i)]
S. 37(1): Business expenditure-Capital or revenue-Product registration expenditure-Revenue expenditure.
S. 37(1) : Business expenditure-Huge expenses of purchases, job-work payment, petrol and transport expenses Compared to preceding year-Failure to discharge the onus-Addition is affirmed.
S.37(1): Business expenditure-Capital or revenue-Stock brokerage-Expenditure on broadband, lease rent, software customisation, facility management, repair and maintenance-Allowable as revenue expenditure. [S. 32, 40(a)(ia)]
S. 36(1)(va): Any sum received from employees-Delayed payment of employees contribution to Employees’ State Insurance Corporation-Disallowance is affirmed.[S.43B]
S. 36(1)(iii) : Interest on borrowed capital-Sufficient interest free funds-Disallowance is deleted.
S. 36(1)(iii) :Interest on borrowed capital-Higher rate of interest 16% to bank on loans-Rate charged to subsidiaries lesser rate of 6%-Disallowance is deleted.