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 ITAT ruled that professional fees paid for drafting patent applications constitute revenue expenditure deductible under s.37(1) as they were incurred in the regular course of business without creating any specific intangible asset. Similarly, translation expenses for software development were held to be revenue expenditure as they were customer-specific, created no new asset, offered no enduring benefit, and were incurred to facilitate sales rather than develop software. Regarding s.14A disallowance, the Tribunal limited the disallowance to Rs.1,210/- (the amount of exempt dividend income earned) following Joint Investment (P.) Ltd., and deleted the remaining disallowance of Rs.1,02,574/-.
The ITAT ruled that professional fees paid for drafting patent applications constitute revenue expenditure deductible under s.37(1) as they were incurred in the regular course of business without creating any specific intangible asset. Similarly, translation expenses for software development were held to be revenue expenditure as they were customer-specific, created no new asset, offered no enduring benefit, and were incurred to facilitate sales rather than develop software. Regarding s.14A disallowance, the Tribunal limited the disallowance to Rs.1,210/- (the amount of exempt dividend income earned) following Joint Investment (P.) Ltd., and deleted the remaining disallowance of Rs.1,02,574/-.
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