Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
Expenditure u/s 10(1) - proof of agricultural operation being carried out in raising clonal plants, Sugarcane and coconuts - CIT(A) and ITAT allowed the relief - The circular will not have any effect on the assessee’s case as on facts, the Commissioner Appeals has noted the submission of the assessee that in order to cultivate the seeds the assessee engages in the activities of preparing of land, levelling, preparation of beds, sowing of seeds, planting etc. and after a certain stage the best responsive plant is earmarked as the mother seed. Therefore, de hors the circular issued by CBDT, the conclusion arrived at by the Tribunal, affirming the view taken by the Commissioner of Income Tax (Appeal), cannot be faulted. - HC
Expenditure u/s 10(1) - proof of agricultural operation being carried out in raising clonal plants, Sugarcane and coconuts - CIT(A) and ITAT allowed the relief - The circular will not have any effect on the assessee’s case as on facts, the Commissioner Appeals has noted the submission of the assessee that in order to cultivate the seeds the assessee engages in the activities of preparing of land, levelling, preparation of beds, sowing of seeds, planting etc. and after a certain stage the best responsive plant is earmarked as the mother seed. Therefore, de hors the circular issued by CBDT, the conclusion arrived at by the Tribunal, affirming the view taken by the Commissioner of Income Tax (Appeal), cannot be faulted. - HC
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