Disallowance of commission expenses due to lack of evidence ...

Commission and depreciation disallowances removed; transfer pricing and deduction computations remanded for further review.

July 16, 2024

Case Laws Income Tax AT

Disallowance of commission expenses due to lack of evidence regarding services rendered. Valuation of construction work-in-progress issue dismissed as academic. Provision for foreseeable losses disallowed, appellant directed to provide evidence of completed projects and revenue offered. Addition u/s 40A(9) deleted based on tribunal's prior order. Depreciation disallowance deleted as transaction was slump sale. Disallowance u/s 14A deleted as investments made from own funds. Receipt from extinguishment of sales tax deferred loan liability held as capital. Transfer pricing adjustment on reimbursement of project cost overrun remanded for ALP determination. Transfer pricing provisions applicable despite pre-existing contract. Computation of deductions u/ss 80HHC and 80HHE remanded. Disallowance u/s 14A for book profit deleted.

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Disallowance of commission expenses due to lack of evidence ...

Commission and depreciation disallowances removed; transfer pricing and deduction computations remanded for further review.

July 16, 2024

Case Laws Income Tax AT

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