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...
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The ITAT upheld the CIT(A)'s order regarding three additions made by the Assessing Officer. Firstly, the receipt treated as consultancy income was rightly held to be a booking advance by the CIT(A) as no evidence of consultancy services was found and no TDS was deducted. Secondly, the addition for overstatement of purchases was correctly deleted by the CIT(A) after considering the assessee's explanation and finding no disparity between book data and sundry creditor details. Thirdly, the CIT(A)'s deletion of addition for unexplained expenditure was upheld as the chart for loan repayments through banking channels was based on bank statements filed during assessment, and the Revenue failed to controvert these factual findings.
The ITAT upheld the CIT(A)'s order regarding three additions made by the Assessing Officer. Firstly, the receipt treated as consultancy income was rightly held to be a booking advance by the CIT(A) as no evidence of consultancy services was found and no TDS was deducted. Secondly, the addition for overstatement of purchases was correctly deleted by the CIT(A) after considering the assessee's explanation and finding no disparity between book data and sundry creditor details. Thirdly, the CIT(A)'s deletion of addition for unexplained expenditure was upheld as the chart for loan repayments through banking channels was based on bank statements filed during assessment, and the Revenue failed to controvert these factual findings.
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