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 considered a case involving denial of exemption u/s 10(38) for alleged bogus LTCG. The assessee invested in shares of a company deemed unreliable due to manipulation by brokers for undue benefits. The ITAT emphasized that profit magnitude does not establish the genuineness of an investee company. Despite the assessee's small profit, it was held that the transaction's genuineness cannot be determined solely by profit amount. The ITAT upheld the decision of the CIT (Appeals), dismissing the assessee's appeal based on the lack of error in the earlier order.
The ITAT considered a case involving denial of exemption u/s 10(38) for alleged bogus LTCG. The assessee invested in shares of a company deemed unreliable due to manipulation by brokers for undue benefits. The ITAT emphasized that profit magnitude does not establish the genuineness of an investee company. Despite the assessee's small profit, it was held that the transaction's genuineness cannot be determined solely by profit amount. The ITAT upheld the decision of the CIT (Appeals), dismissing the assessee's appeal based on the lack of error in the earlier order.
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