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...
Regarding additions u/s 14A for disallowance of expenditure related to exempt income, the ITAT upheld the CIT(A)'s order, which modified the Assessing Officer's (AO) disallowance by excluding investments not yielding exempt income, in accordance with the law. The ITAT rejected the assessee's claim for accepting its suo moto disallowance. On the issue of short credit of TDS, the ITAT directed the AO to grant relief expeditiously as per the CIT(A)'s directions. Concerning short credit of Dividend Distribution Tax (DDT), the ITAT dismissed the ground, stating that the matter requires administrative resolution between the assessee and the Revenue authorities. Regarding denial of foreign tax credit u/s 90/91, the ITAT directed the AO to consider the assessee's case and pass a suitable order. On the allowability of ESOP compensation as revenue expenditure, the ITAT upheld the CIT(A)'s order, following the coordinate bench's decision in the assessee's own case for earlier years.
Regarding additions u/s 14A for disallowance of expenditure related to exempt income, the ITAT upheld the CIT(A)'s order, which modified the Assessing Officer's (AO) disallowance by excluding investments not yielding exempt income, in accordance with the law. The ITAT rejected the assessee's claim for accepting its suo moto disallowance. On the issue of short credit of TDS, the ITAT directed the AO to grant relief expeditiously as per the CIT(A)'s directions. Concerning short credit of Dividend Distribution Tax (DDT), the ITAT dismissed the ground, stating that the matter requires administrative resolution between the assessee and the Revenue authorities. Regarding denial of foreign tax credit u/s 90/91, the ITAT directed the AO to consider the assessee's case and pass a suitable order. On the allowability of ESOP compensation as revenue expenditure, the ITAT upheld the CIT(A)'s order, following the coordinate bench's decision in the assessee's own case for earlier years.
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