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...
The High Court remanded the proceedings to the Assessing Officer to consider the assessee's alternate claim for loss arising out of Held till Maturity securities under the head 'income from business and profession'. The Income Tax Appellate Tribunal's finding that no material was supplied by the assessee to substantiate the claim was held unsustainable. The assessee accepted the Income Tax Appellate Tribunal's decision treating profits from the sale of Held till Maturity securities as capital gains.
The High Court remanded the proceedings to the Assessing Officer to consider the assessee's alternate claim for loss arising out of Held till Maturity securities under the head 'income from business and profession'. The Income Tax Appellate Tribunal's finding that no material was supplied by the assessee to substantiate the claim was held unsustainable. The assessee accepted the Income Tax Appellate Tribunal's decision treating profits from the sale of Held till Maturity securities as capital gains.
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