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...
ITAT allowed the taxpayer's claim for deduction of expenditure incurred in an abandoned project, recognizing that the project abandonment was due to reasons beyond the assessee's control. The tribunal held that the written-off expenses under 'work in progress' were commercially justified and not subject to tax authority scrutiny. The tribunal directed the Assessing Officer to delete the disallowance in both the section 143(1) intimation and section 143(3) assessment order, effectively permitting the expenditure deduction based on the commercial reasonableness of the assessee's decision.
ITAT allowed the taxpayer's claim for deduction of expenditure incurred in an abandoned project, recognizing that the project abandonment was due to reasons beyond the assessee's control. The tribunal held that the written-off expenses under 'work in progress' were commercially justified and not subject to tax authority scrutiny. The tribunal directed the Assessing Officer to delete the disallowance in both the section 143(1) intimation and section 143(3) assessment order, effectively permitting the expenditure deduction based on the commercial reasonableness of the assessee's decision.
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