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...
The ITAT Ahmedabad ruled on two key issues: 1) Determination of Selling Price of Shares for LTCG Calculation - Held that the AR's contention regarding higher consideration for shareholders who were tenants is justifiable. Section 50C not applicable to share of Private Limited Company. Decision of CIT vs. Salora International Limited not applicable due to distinguishing facts. 2) Deduction of rent paid against HRA - Assessee provided evidence of paying rent to HUF. Allowed deduction based on Tribunal decisions. Grounds 1 and 2 allowed.
The ITAT Ahmedabad ruled on two key issues: 1) Determination of Selling Price of Shares for LTCG Calculation - Held that the AR's contention regarding higher consideration for shareholders who were tenants is justifiable. Section 50C not applicable to share of Private Limited Company. Decision of CIT vs. Salora International Limited not applicable due to distinguishing facts. 2) Deduction of rent paid against HRA - Assessee provided evidence of paying rent to HUF. Allowed deduction based on Tribunal decisions. Grounds 1 and 2 allowed.
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