Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
The Appellate Tribunal addressed undisclosed sales and net profit determination. The CIT(A) limited the addition to the net profit element, with the Revenue arguing for a 12.5% rate instead of 8%. Incriminating material was found during a search at the director's residence, indicating off-the-books sales. The Tribunal ruled that a higher net profit rate must be justified based on business nature and facts, not arbitrarily. The Revenue failed to provide a reasonable basis for the 12.5% rate, and the High Court decision cited did not align with the assessee's activities. The Tribunal rejected the Revenue's argument, upholding the CIT(A)'s decision.
The Appellate Tribunal addressed undisclosed sales and net profit determination. The CIT(A) limited the addition to the net profit element, with the Revenue arguing for a 12.5% rate instead of 8%. Incriminating material was found during a search at the director's residence, indicating off-the-books sales. The Tribunal ruled that a higher net profit rate must be justified based on business nature and facts, not arbitrarily. The Revenue failed to provide a reasonable basis for the 12.5% rate, and the High Court decision cited did not align with the assessee's activities. The Tribunal rejected the Revenue's argument, upholding the CIT(A)'s decision.
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