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...
Business expenses - CSR - The expenditure could be related to ‘Commercial Expediency’, as any amount contributed to the BATF would generate goodwill of the local community as well as the Government Authorities. It must also be emphasised that the concept of ‘Commercial Expediency’ is from the perspective of an assessee and cannot be judged from the perspective of what the Revenue construes it to be ‘Commercial expediency.’ - As the subject matter of dispute relates to assessment year 2010-11, it can be stated that the said explanation to Section 37 of the I.T. Act would not apply as regards the present subject matter of dispute. - HC
Business expenses - CSR - The expenditure could be related to ‘Commercial Expediency’, as any amount contributed to the BATF would generate goodwill of the local community as well as the Government Authorities. It must also be emphasised that the concept of ‘Commercial Expediency’ is from the perspective of an assessee and cannot be judged from the perspective of what the Revenue construes it to be ‘Commercial expediency.’ - As the subject matter of dispute relates to assessment year 2010-11, it can be stated that the said explanation to Section 37 of the I.T. Act would not apply as regards the present subject matter of dispute. - HC
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