Delhi ITAT allows deduction
u/s. 37(1) to PepsiCo India (assessee) for sponsorship fees paid to ICC during
AY 2009-10; Rejects Revenue’s stand that since the expenditure benefitted other
group entities across the globe, it could not be said to have been incurred
wholly and exclusively for the business of the assessee; ITAT clarifies that
“Benefit factor to other related parties is relevant under transfer pricing
provision and not while allowability of business expense u/s. 37(1)”; Observes
that the commercial expediency was not disputed, further acknowledges that
owing to large viewership of Cricket, advertising on such platforms is common;
Separately, treats subsidy received under West Bengal Incentive Scheme of 2004
as a capital receipt as it was given for the purpose of industrialization of
the State, notes that it was based upon fixed capital investment made by
assessee and only the mode of disbursement was in the form of re-payment of
sales tax paid.:ITAT
Subscribe to:
Post Comments (Atom)
Navigating the Complexities of GST Pre-deposit Requirements Before GSTAT
The introduction of the Goods and Services Tax Appellate Tribunal (GSTAT) has brought significant changes to the pre-deposit framework for...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
Issue before the Income-tax Appellate Tribunal (ITAT) Whether the phrase “paid up capital and general reserves” should be defined as “Ne...
-
Introduction Employee welfare is a cornerstone of corporate responsibility, and gratuity forms a critical part of the social security benefi...
-
Sr No Due Date Related to Compliance to be made 1. 11.06.2026 GST ...
-
In the complex landscape of India’s Goods and Services Tax (GST), the tax treatment of non-compete fees has emerged as a critical area f...
-
Selling a property can trigger a significant tax liability in the form of capital gains tax. However, the Income-tax Act, 1961, allows you...
-
Capital gains taxation on immovable property under the Income-tax Act, 1961 often turns on a deceptively simple question: when is a proper...
-
Tax Deducted at Source (TDS) is generally not applicable to interchange fees, payment gateway charges, or the Merchant Discount Rate (MDR)...
-
The newly enacted Income Tax Act, 2025, marks a significant step toward simplification by consolidating multiple presumptive taxation sche...
-
Introduction The law relating to companies is laid down in Companies Act, 2013 and the rules made thereunder and t...
No comments:
Post a Comment