Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
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