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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ITAT dismissed revenue's appeal concerning disputed long-term capital gains from penny stock transactions. While AO treated gains as unexplained cash credits under Section 68, assessee successfully demonstrated transaction legitimacy through comprehensive documentation including bank statements, contract notes, demat records and audited financials. Revenue failed to establish price manipulation or collusion with counterparties through direct evidence. Mere suspicion of accommodation entries in penny stocks insufficient to sustain addition without concrete proof rebutting assessee's evidence. CIT(A)'s deletion of addition upheld as assessee discharged onus of proving genuine nature of LTCG while revenue relied on generalized allegations without substantive material establishing non-genuineness.
ITAT dismissed revenue's appeal concerning disputed long-term capital gains from penny stock transactions. While AO treated gains as unexplained cash credits under Section 68, assessee successfully demonstrated transaction legitimacy through comprehensive documentation including bank statements, contract notes, demat records and audited financials. Revenue failed to establish price manipulation or collusion with counterparties through direct evidence. Mere suspicion of accommodation entries in penny stocks insufficient to sustain addition without concrete proof rebutting assessee's evidence. CIT(A)'s deletion of addition upheld as assessee discharged onus of proving genuine nature of LTCG while revenue relied on generalized allegations without substantive material establishing non-genuineness.
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