Restriction on royalty deductions applies to the entire previous year, not prorated from the June reference. The restriction on deductions for royalty and fees for technical services under section 44D applies to the entire previous year relevant to the assessment year beginning 1977-78 and thereafter; the June 1 date is relevant only to withholding procedures and merely regularises deductions permitted up to May 31, 1976. Assessing officers must apply the deduction cap for the whole previous year and correct any assessments where the cap was applied pro rata.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Restriction on royalty deductions applies to the entire previous year, not prorated from the June reference.
The restriction on deductions for royalty and fees for technical services under section 44D applies to the entire previous year relevant to the assessment year beginning 1977-78 and thereafter; the June 1 date is relevant only to withholding procedures and merely regularises deductions permitted up to May 31, 1976. Assessing officers must apply the deduction cap for the whole previous year and correct any assessments where the cap was applied pro rata.
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