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 disallowance of advertisement expenses lacked merit as the charges were reasonable. The 15% discount received by the agent did not impact the reasonableness of charges borne by the assessee. However, hoarding expenses lacked substantiation, requiring further verification. The matter was remanded to the AO for review. Similarly, addition on commission and brokerage expenses needed reevaluation with proper substantiation. The AO's disallowance of depreciation on fixed assets was overturned as the assessee was entitled to claim depreciation under section 32 of the Act.
The ITAT held that disallowance of advertisement expenses lacked merit as the charges were reasonable. The 15% discount received by the agent did not impact the reasonableness of charges borne by the assessee. However, hoarding expenses lacked substantiation, requiring further verification. The matter was remanded to the AO for review. Similarly, addition on commission and brokerage expenses needed reevaluation with proper substantiation. The AO's disallowance of depreciation on fixed assets was overturned as the assessee was entitled to claim depreciation under section 32 of the Act.
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