rights and duties of the concerned partners vis-a-vis the GDR issue, warranties, approvals to be obtained, delivery of GDRs, payment, opinions ... payment to the underwriters/managers, they would successfully put through the GDR issue ?
(b) If both the purchase and resale theory and the finished package
International Finance Corporation, Washington as Joint Lead Managers to the GDR issue. The agreement entered by the assessee with the Lead Managers as per approval ... effected on the money paid for availing the certificate relating to GDR issue, by issuing notice dated 5-1-1999 requiring the assessee to show
Allowing deduction under section 35D of the Act in respect
of GDR issue expenses: Rs. 1, 17, 19,960
63. Ground no. 1 raised ... Ground No.(k) which is in respect of allowing expenses on GDR issue
as covered in section 35D , Ld. AR of the assessee submitted that
2002
Bajaj Holdings Investment Ltd
(k) Erred in allowing expenses on GDR issue as covered in Sec.
35D even though these expenses cannot be said
issue of taxability is not fully discussed in the
order of the assessing officer and the CIT(A) therefore we restore this
issue ... GDR issue expenses: Rs.1,17,19,960/-:
54. The assessee incurred expenses in connection with the issue of
Global Depository Receipts (GDR
issue of taxability is not fully discussed in the
order of the assessing officer and the CIT(A) therefore we restore this
issue ... GDR issue expenses: Rs.1,17,19,960/-:
54. The assessee incurred expenses in connection with the issue of
Global Depository Receipts (GDR
respect of
allowing deduction under section 35D in respect of GDR issue expenses,
Ld.AR of the assessee brought to our notice that the issue ... Ground No. (k) which is in respect of allowing
expenses on GDR issue as covered in section 35D, Ld. AR of the
assessee submitted that
respect of
allowing deduction under section 35D in respect of GDR issue expenses,
Ld.AR of the assessee brought to our notice that the issue ... Ground No. (k) which is in respect of allowing
expenses on GDR issue as covered in section 35D, Ld. AR of the
assessee submitted that
were also utilised by Indian companies outside India for their
ADR/GDR issues. It was submitted that the assessee, being a non-
resident, carried ... received commission
for acting as lead manager and underwriter for ADR/GDR issues of
Indian companies outside India. It is submitted that ADR (American
Depository
penalty has been levied on the disallowance of expenditure on GDR issue
to the tune of Rs.3,00,000/-. Vide show-cause notice dated ... penalty should not be levied on the disallowance
of expenditure on GDR issue. The assessee replied that it has neither concealed any
particulars of income
