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...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
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