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...
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
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