Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
The Appellate Tribunal addressed two key issues: 1. Denial of cost of improvement in LTCG computation: AO's denial based on absence of improvement reference in sale deed and payment timing after notice issuance. Tribunal upheld CIT(A)'s deletion, noting AO's similar addition in spouse's case and lack of Revenue challenge. 2. Denial of deduction u/s 54: AO's denial due to alleged failure to meet construction deadline. Tribunal affirmed CIT(A)'s finding of asset sale, purchase, and compliance with u/s 54 conditions. Spouse's case comparison showed inconsistency. Tribunal ruled in favor of taxpayer, dismissing Revenue's grounds.
The Appellate Tribunal addressed two key issues: 1. Denial of cost of improvement in LTCG computation: AO's denial based on absence of improvement reference in sale deed and payment timing after notice issuance. Tribunal upheld CIT(A)'s deletion, noting AO's similar addition in spouse's case and lack of Revenue challenge. 2. Denial of deduction u/s 54: AO's denial due to alleged failure to meet construction deadline. Tribunal affirmed CIT(A)'s finding of asset sale, purchase, and compliance with u/s 54 conditions. Spouse's case comparison showed inconsistency. Tribunal ruled in favor of taxpayer, dismissing Revenue's grounds.
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