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...
Allowability of Interest Expenditure - The Tribunal noted a delay of 418 days in filing the quantum appeal by the assessee, which was condoned as the assessee pursued an alternative legal remedy before the Commissioner of Income Tax (Appeals) [CIT(A)]. - The main issue was the disallowance of interest on the grounds that borrowed funds were utilized for non-business purposes. The Tribunal found that the CIT(A) did not appropriately consider the remand report from the Assessing Officer (AO), which detailed the utilization of borrowed funds. Therefore, the Tribunal restored the quantum appeal to the file of the CIT(A) for re-adjudication in light of the AO's remand report. - AT
Allowability of Interest Expenditure - The Tribunal noted a delay of 418 days in filing the quantum appeal by the assessee, which was condoned as the assessee pursued an alternative legal remedy before the Commissioner of Income Tax (Appeals) [CIT(A)]. - The main issue was the disallowance of interest on the grounds that borrowed funds were utilized for non-business purposes. The Tribunal found that the CIT(A) did not appropriately consider the remand report from the Assessing Officer (AO), which detailed the utilization of borrowed funds. Therefore, the Tribunal restored the quantum appeal to the file of the CIT(A) for re-adjudication in light of the AO's remand report. - AT
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