Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Broken period amount received on transfer of non-convertible debentures retained the character of interest, even though it was paid by the purchaser rather than the issuer, because the NCDs were transferred on a cum-interest basis and the amount represented accrued return for the intervening period. The Tribunal held that the source of payment did not change the intrinsic character of the receipt. The amount was therefore assessable as interest under the head 'Income from Other Sources', and the assessee's appeal failed.
Broken period amount received on transfer of non-convertible debentures retained the character of interest, even though it was paid by the purchaser rather than the issuer, because the NCDs were transferred on a cum-interest basis and the amount represented accrued return for the intervening period. The Tribunal held that the source of payment did not change the intrinsic character of the receipt. The amount was therefore assessable as interest under the head 'Income from Other Sources', and the assessee's appeal failed.
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