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...
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Validity of Adjustment done by the CPC u/s 143 (1)(a)(v) - Deduction u/s 80P disallowed - Prior to amendment in deduction u/s 143(1)(a)(v) by Finance Act on 01.04.2021, the disallowance of deduction was limited to sections 10AA, 80IA, 80IAB, 80IB, 80IC, 80ID and 80IE. Thus, the deduction claimed u/s 80P was not mentioned there. - The Tribunal found that the CPC's adjustment was not permissible.
Validity of Adjustment done by the CPC u/s 143 (1)(a)(v) - Deduction u/s 80P disallowed - Prior to amendment in deduction u/s 143(1)(a)(v) by Finance Act on 01.04.2021, the disallowance of deduction was limited to sections 10AA, 80IA, 80IAB, 80IB, 80IC, 80ID and 80IE. Thus, the deduction claimed u/s 80P was not mentioned there. - The Tribunal found that the CPC's adjustment was not permissible.
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