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...
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
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