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...
Disallowance of set off of Loss - sale of equity shares (STT) - short-term capital gains (STCG) on sale of derivatives and short-term capital loss (STCL) - The Tribunal examined various judicial pronouncements and held that under section 70(2) of the Act, STCL arising from any asset can be set off against STCG arising from any other asset under a similar computation, regardless of the differential tax rates. It emphasized that the computation in both cases is made under the same provisions, allowing for such set-off. Consequently, the Tribunal allowed the appeal of the assessee, affirming their right to set off STCL against STCG.
Disallowance of set off of Loss - sale of equity shares (STT) - short-term capital gains (STCG) on sale of derivatives and short-term capital loss (STCL) - The Tribunal examined various judicial pronouncements and held that under section 70(2) of the Act, STCL arising from any asset can be set off against STCG arising from any other asset under a similar computation, regardless of the differential tax rates. It emphasized that the computation in both cases is made under the same provisions, allowing for such set-off. Consequently, the Tribunal allowed the appeal of the assessee, affirming their right to set off STCL against STCG.
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