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 upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
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