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...
Addition u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
Addition u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
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