Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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/-.
Note: It is a system-generated summary and is for quick reference only.