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 adjudicated a multi-issue tax dispute involving conversion of stock-in-trade into capital assets, commission payments, and share transfer transactions. The tribunal held that conversion of stock-in-trade into capital assets is permissible without tax implications, particularly before 2018 legislative amendments. Commission payments made through banking channels with appropriate TDS were validated. Regarding share transactions, ITAT rejected revenue's challenge to short-term capital loss, finding the share purchases through stock exchange as genuine, notwithstanding SEBI inquiries. The tribunal ultimately allowed the assessee's appeal, granting long-term capital gains treatment with indexation benefit and accepting commission and share transaction claims.
ITAT adjudicated a multi-issue tax dispute involving conversion of stock-in-trade into capital assets, commission payments, and share transfer transactions. The tribunal held that conversion of stock-in-trade into capital assets is permissible without tax implications, particularly before 2018 legislative amendments. Commission payments made through banking channels with appropriate TDS were validated. Regarding share transactions, ITAT rejected revenue's challenge to short-term capital loss, finding the share purchases through stock exchange as genuine, notwithstanding SEBI inquiries. The tribunal ultimately allowed the assessee's appeal, granting long-term capital gains treatment with indexation benefit and accepting commission and share transaction claims.
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