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...
Characterization of receipts - Treatment of interest income from staff loans and advances, interest income from other loans and advances and miscellaneous income - Classification as Business Income vs. Other Income - Despite the assessee's assertion that the loans to employees were part of a business strategy to retain talent and the miscellaneous income arose from routine business activities, the ITAT found the Revenue's argument persuasive. Specifically, it highlighted that the income did not directly result from the assessee's primary business activities and that separate heads for interest income in the return of income necessitate its inclusion under "Other Income."
Characterization of receipts - Treatment of interest income from staff loans and advances, interest income from other loans and advances and miscellaneous income - Classification as Business Income vs. Other Income - Despite the assessee's assertion that the loans to employees were part of a business strategy to retain talent and the miscellaneous income arose from routine business activities, the ITAT found the Revenue's argument persuasive. Specifically, it highlighted that the income did not directly result from the assessee's primary business activities and that separate heads for interest income in the return of income necessitate its inclusion under "Other Income."
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