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...
Interest on inter-corporate deposits was treated as accrued because no new evidence rebutted the appellate finding. Disallowance relating to investment in a limited liability partnership under section 14A and rule 8D was likewise sustained for lack of contrary material. The genuineness of loans alleged to be connected with bank-related kickbacks requires verification of the final Special CBI Court proceedings and their effect on the transactions; that issue was remanded without a merits finding. Capital losses on unquoted-share sales were accepted where valuation followed the book value method under rule 11UA read with section 50CA, no specific defect in the valuer's report was identified, and no registered-valuer reference was made.
Interest on inter-corporate deposits was treated as accrued because no new evidence rebutted the appellate finding. Disallowance relating to investment in a limited liability partnership under section 14A and rule 8D was likewise sustained for lack of contrary material. The genuineness of loans alleged to be connected with bank-related kickbacks requires verification of the final Special CBI Court proceedings and their effect on the transactions; that issue was remanded without a merits finding. Capital losses on unquoted-share sales were accepted where valuation followed the book value method under rule 11UA read with section 50CA, no specific defect in the valuer's report was identified, and no registered-valuer reference was made.
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