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, an Appellate Tribunal, addressed two main issues. Firstly, regarding the computation of book profit u/s 115JB, discrepancies arose from the deduction claimed by the assessee for brought forward losses or unabsorbed depreciation. The Tribunal directed a fresh verification by the Assessing Officer based on the provided chart. Secondly, concerning TDS u/s 195 for payments to non-residents, the Tribunal held that payments to certain countries were not taxable in India under treaty provisions, thus no tax deduction was required. Additionally, the Tribunal ruled in favor of the assessee regarding disallowance of advances written off, as supported by the Commissioner (Appeals)'s factual findings.
The ITAT, an Appellate Tribunal, addressed two main issues. Firstly, regarding the computation of book profit u/s 115JB, discrepancies arose from the deduction claimed by the assessee for brought forward losses or unabsorbed depreciation. The Tribunal directed a fresh verification by the Assessing Officer based on the provided chart. Secondly, concerning TDS u/s 195 for payments to non-residents, the Tribunal held that payments to certain countries were not taxable in India under treaty provisions, thus no tax deduction was required. Additionally, the Tribunal ruled in favor of the assessee regarding disallowance of advances written off, as supported by the Commissioner (Appeals)'s factual findings.
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