S. 40(a)(ia) : Amounts not deductible-Deduction at source-Provision on account of commission payment to an agent-Accepted in earlier years-Deletion of disallowance is held to be justified.
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Provision on account of commission payment to an agent-Accepted in earlier years-Deletion of disallowance is held to be justified.
S. 37(1) : Business expenditure-Consultancy fees-Studying and preparing a strategy to reduce cost of production-Allowable as revenue expenditure.
S. 37(1) : Business expenditure-Provision for wage arrears-Allowable as deduction. [S. 28(i), 145]
S. 37(1) : Business expenditure-Manufacturer of sports products-Advertisement-Training to pace bowlers-Allowable as business expenditure.
S. 28(va) : Business income-Compensation received for refraining from carrying on competitive business-Capital receipt-Prior to 1-4-2003. [S. 4]
S. 12AA : Procedure for registration-Trust or institution-Capitalisation fee-Misuse of funds-Cancellation of registration is held to be valid. [S. 11, 12, 12A, 12AA(3), Art. 226]
S. 11 : Property held for charitable purposes-Depreciation-Application of income-Entitle to claim depreciation. [S. 32]
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Offshore supply of equipments-Transferred outside India and entire sale was executed outside India-Revenue received therefrom was not to be taxed in India-Basic engineering design services were intrinsically in respect of setting up of Butane-1 plant and same were rendered through project office of assessee in India, consideration received in respect of said basic engineering design services was liable to tax in India as business income of PE of assessee-DTAA-India-France. [Art. 7(1), 12]
S. 2(22)(e) : Deemed dividend-Loans and advance-Provision is applicable-Matter remanded to Tribunal to decide on merit. [S. 260A]
Direct Tax Vivad Se Vishwas Act, 2020 .
S. 4 : Filing of declaration and particulars to be furnished – Tribunal recalled its order , restored appeal and posted it for fresh hearing- Doctrine of relation back were to be applied- Pendency of appeal of revenue before Appellate Tribunal- Rejection of application is held to be not valid [ Art , 226 ]
Direct Tax Vivad Se Vishwas Act, 2020 .
S. 4 : Filing of declaration and particulars to be furnished – Tribunal recalled its order , restored appeal and posted it for fresh hearing- Doctrine of relation back were to be applied- Pendency of appeal of revenue before Appellate Tribunal- Rejection of application is held to be not valid [ Art , 226 ]