Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
The Appellate Tribunal upheld the addition u/s 68 as the assessee failed to establish the identity, creditworthiness, and genuineness of transactions with Shri Singla due to lack of documentary evidence like ITR, Bank Statement, and confirmation. The First Appellate Authority's decision to confirm the addition was deemed appropriate given the absence of support from the assessee. Regarding the addition u/s 56(2)(vii)(c) for the variance between fair market value and actual consideration paid for shares, the Tribunal upheld the AO's decision based on the fair market value calculation in accordance with relevant sections of the Income Tax Act. The First Appellate Authority's confirmation of this addition was also upheld as justified and not warranting interference.
The Appellate Tribunal upheld the addition u/s 68 as the assessee failed to establish the identity, creditworthiness, and genuineness of transactions with Shri Singla due to lack of documentary evidence like ITR, Bank Statement, and confirmation. The First Appellate Authority's decision to confirm the addition was deemed appropriate given the absence of support from the assessee. Regarding the addition u/s 56(2)(vii)(c) for the variance between fair market value and actual consideration paid for shares, the Tribunal upheld the AO's decision based on the fair market value calculation in accordance with relevant sections of the Income Tax Act. The First Appellate Authority's confirmation of this addition was also upheld as justified and not warranting interference.
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