Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
The ITAT held that expenses claimed u/s 57(iii) lacked nexus with interest income earned on fixed deposits. The interest expenditure was for liquidation expenses, not for earning interest income. Liquidation expenses did not relate to interest income, so not allowable u/s 57(iii). Liquidator's contention that all expenses incurred during liquidation, including interest paid on loans, were allowable was rejected. Set off of losses against income from other sources dismissed due to disallowed expenses. Short term capital gains treated as long term for concessional tax rate u/s 112(1) of the Act.
The ITAT held that expenses claimed u/s 57(iii) lacked nexus with interest income earned on fixed deposits. The interest expenditure was for liquidation expenses, not for earning interest income. Liquidation expenses did not relate to interest income, so not allowable u/s 57(iii). Liquidator's contention that all expenses incurred during liquidation, including interest paid on loans, were allowable was rejected. Set off of losses against income from other sources dismissed due to disallowed expenses. Short term capital gains treated as long term for concessional tax rate u/s 112(1) of the Act.
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