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...
HC dismissed the revenue appeal, rejecting the disallowance of depreciation on securities and pension fund contributions. The court found no merit in the revenue's contention under Section 14A and Rule 8D, particularly noting that the shares were held as stock in trade, rendering the provisions inapplicable. The decision aligned with prior judicial precedent from the coordinate bench, effectively upholding the assessee's position on depreciation and pension fund contributions.
HC dismissed the revenue appeal, rejecting the disallowance of depreciation on securities and pension fund contributions. The court found no merit in the revenue's contention under Section 14A and Rule 8D, particularly noting that the shares were held as stock in trade, rendering the provisions inapplicable. The decision aligned with prior judicial precedent from the coordinate bench, effectively upholding the assessee's position on depreciation and pension fund contributions.
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