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...
Allowability of Derivative loss - separate addition on account of alleged payment of margin monies on an estimated basis - The Tribunal emphasized that in derivative transactions, the actual transfer of money under the heads 'purchase and sale' is notional, and only the resultant difference paid or received at the end of the transaction is relevant. The Tribunal recognized that losses incurred in derivative transactions, if paid by the assessee through regular banking channels and adequately evidenced, should not lead to additional disallowance on an estimated basis for alleged payment of margin monies. - AT
Allowability of Derivative loss - separate addition on account of alleged payment of margin monies on an estimated basis - The Tribunal emphasized that in derivative transactions, the actual transfer of money under the heads 'purchase and sale' is notional, and only the resultant difference paid or received at the end of the transaction is relevant. The Tribunal recognized that losses incurred in derivative transactions, if paid by the assessee through regular banking channels and adequately evidenced, should not lead to additional disallowance on an estimated basis for alleged payment of margin monies. - AT
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