Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
Assessee exercised option u/s 115BAA to compute tax liability at lower rate. CPC accepted option for AY 2020-21 but for current year, rectified under s.154 without opportunity to assessee and computed tax at normal rate instead of s.115BAA rate. ITAT held rectification order invalid as assessee didn't violate any provision for s.115BAA. Grounds 1-4 allowed. On TDS issue, ITAT upheld CIT(A)/NFAC order restoring matter to AO for verification, dismissing assessee's ground.
Assessee exercised option u/s 115BAA to compute tax liability at lower rate. CPC accepted option for AY 2020-21 but for current year, rectified under s.154 without opportunity to assessee and computed tax at normal rate instead of s.115BAA rate. ITAT held rectification order invalid as assessee didn't violate any provision for s.115BAA. Grounds 1-4 allowed. On TDS issue, ITAT upheld CIT(A)/NFAC order restoring matter to AO for verification, dismissing assessee's ground.
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