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...
Computation of deduction u/s 10AA - The Tribunal examined the details provided by the assessee regarding expenses incurred in foreign currency. It noted that the Assessing Officer had excluded these expenses without thorough examination. The Tribunal referred to a previous decision by the Madras High Court in a similar case and held that the order of the Commissioner of Income Tax (Appeals) was not justified in confirming the exclusion. It allowed the appeal on this ground.
Computation of deduction u/s 10AA - The Tribunal examined the details provided by the assessee regarding expenses incurred in foreign currency. It noted that the Assessing Officer had excluded these expenses without thorough examination. The Tribunal referred to a previous decision by the Madras High Court in a similar case and held that the order of the Commissioner of Income Tax (Appeals) was not justified in confirming the exclusion. It allowed the appeal on this ground.
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