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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HC held that Section 50C's applicability extends beyond traditional ownership, encompassing various modes of property holding including leasehold rights. The term "held by an assessee" is interpreted broadly to include multiple legal arrangements such as leasehold, sub-leasehold, tenancy, and licensee interests. The court emphasized that the method of holding land does not create exceptions to tax provisions. The word 'transfer' under Section 50C must be construed with wide amplitude, covering all legally permissible transfer methods. Consequently, the court dismissed the appeal, affirming a comprehensive interpretation of property transfer and taxation principles.
HC held that Section 50C's applicability extends beyond traditional ownership, encompassing various modes of property holding including leasehold rights. The term "held by an assessee" is interpreted broadly to include multiple legal arrangements such as leasehold, sub-leasehold, tenancy, and licensee interests. The court emphasized that the method of holding land does not create exceptions to tax provisions. The word 'transfer' under Section 50C must be construed with wide amplitude, covering all legally permissible transfer methods. Consequently, the court dismissed the appeal, affirming a comprehensive interpretation of property transfer and taxation principles.
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