Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
The Appellate Tribunal held that the addition of Rs. 51.20 lacs as unexplained investment u/ss 69 or 56(2)(x)/6(2)(vii) was unjustified as there was no evidence of actual payment to vendors. Section 69 requires actual investment, not just stamp value. The lower authorities erred in making the addition, which is not taxable for a partnership firm u/s 56(2)(x) for the relevant assessment year. The decision favored the assessee, and the appeal was allowed.
The Appellate Tribunal held that the addition of Rs. 51.20 lacs as unexplained investment u/ss 69 or 56(2)(x)/6(2)(vii) was unjustified as there was no evidence of actual payment to vendors. Section 69 requires actual investment, not just stamp value. The lower authorities erred in making the addition, which is not taxable for a partnership firm u/s 56(2)(x) for the relevant assessment year. The decision favored the assessee, and the appeal was allowed.
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