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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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The assessee's short-term capital gains from share trading were rightly treated as business income. Mere mention of shares as investments does not grant benefit under Circular No.4 of 2007. Separate account maintenance, delivery-based transactions, and acceptance of capital gains in preceding years were not sufficient to establish share trading as investments. The assessee was eligible for deduction u/s 80IC as the manufacturing unit was located in a notified area, fulfilling conditions. Disallowance of 20% of milk purchases was unjustified as expenses were duly debited, and net profit ratio was considered for assessment in subsequent years. The Tribunal allowed the assessee's claim, finding no justification for discrediting purchases on an ad hoc basis.
The assessee's short-term capital gains from share trading were rightly treated as business income. Mere mention of shares as investments does not grant benefit under Circular No.4 of 2007. Separate account maintenance, delivery-based transactions, and acceptance of capital gains in preceding years were not sufficient to establish share trading as investments. The assessee was eligible for deduction u/s 80IC as the manufacturing unit was located in a notified area, fulfilling conditions. Disallowance of 20% of milk purchases was unjustified as expenses were duly debited, and net profit ratio was considered for assessment in subsequent years. The Tribunal allowed the assessee's claim, finding no justification for discrediting purchases on an ad hoc basis.
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