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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
The ITAT addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
The ITAT addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
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