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The Appellate Tribunal addressed several issues in the case. ...


Provision for customer loyalty program upheld as scientific method applied. Disallowance u/s 14A set aside due to lack of satisfaction. TDS u/s 195 not applicable for foreign expenditure.

Case Laws     Income Tax

June 7, 2024

The Appellate Tribunal addressed several issues in the case. Firstly, the disallowance of provision for a customer loyalty program was allowed as the method used by the assessee was deemed scientific. Secondly, the disallowance u/s 14A r.w.r. 8D was set aside due to lack of recorded satisfaction by the AO. Thirdly, TDS u/s 195 was not required for professional services rendered abroad for US operations in the relevant assessment year. Fourthly, the issue of loss on closure of a boutique in the United States was remitted back to the AO for verification. Fifthly, the deduction u/s. 80IC for common expenses allocation was disallowed. Lastly, the deduction u/s. 80IC on allocation of expenditure on a trademark was remitted back to the AO for re-adjudication. Additionally, marked to market loss and excess depreciation claimed on UPS were allowed in favor of the assessee.

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