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 held that exemption u/s 10(23C) was disallowed due to non-filing of audit report in Form 10BB. Assessee not registered u/s 10(23), ineligible for exemption. Net income to be taxed after allowable expenditure deduction. Remanded to AO to tax net income after deducting expenses like regular, salary, puja, and admissible expenditure. CIT (A) erred in not addressing eligibility issue. Assessee to be assessed as AOP. Issue of eligibility to claim u/s 10(23) to be reconsidered by CIT (A) with opportunity for assessee to present evidence. Remanded for fresh adjudication.
The ITAT held that exemption u/s 10(23C) was disallowed due to non-filing of audit report in Form 10BB. Assessee not registered u/s 10(23), ineligible for exemption. Net income to be taxed after allowable expenditure deduction. Remanded to AO to tax net income after deducting expenses like regular, salary, puja, and admissible expenditure. CIT (A) erred in not addressing eligibility issue. Assessee to be assessed as AOP. Issue of eligibility to claim u/s 10(23) to be reconsidered by CIT (A) with opportunity for assessee to present evidence. Remanded for fresh adjudication.
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