Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
ITAT held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer's addition under ICDS VI was deleted and the CIT(A)'s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO's reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue's appeal dismissed.
ITAT held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer's addition under ICDS VI was deleted and the CIT(A)'s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO's reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue's appeal dismissed.
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