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 that the subsidy received by the assessee under the new package scheme incentive of 1993 was capital in nature, computed on the basis of fixed capital investment, and hence not taxable. Income from sale of carbon credit was treated as capital and not liable to tax. The deduction u/s 80IA was allowed for the rail system developed by the assessee, computing revenue by savings approach over road freight cost. The assessee was justified in valuing internal transfer at landed cost by obtaining quotation from erstwhile foreign supplier.
The ITAT upheld that the subsidy received by the assessee under the new package scheme incentive of 1993 was capital in nature, computed on the basis of fixed capital investment, and hence not taxable. Income from sale of carbon credit was treated as capital and not liable to tax. The deduction u/s 80IA was allowed for the rail system developed by the assessee, computing revenue by savings approach over road freight cost. The assessee was justified in valuing internal transfer at landed cost by obtaining quotation from erstwhile foreign supplier.
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