Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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ITAT affirmed that the assessee is entitled to deductions under both s.36(1)(vii) and s.36(1)(viia)(c), holding the proviso to s.36(1)(vii) merely caps bad-debt write-offs by the credit balance in provisions to prevent double deduction; factual review showed no excess or duplication, so CIT(A)'s allowance was upheld. On s.14A, the Tribunal directed the AO to confine disallowance to the assessee's suo-motu pro-rata allocation to investment-department costs, rejecting the AO's challenge absent specific contrary accounting findings. Deductions under s.36(1)(viii) were held independent of s.36(1)(viia)(c) computations. The amortised rent issue was remitted to the AO for reconsideration under s.158A upon Form-8 compliance.
ITAT affirmed that the assessee is entitled to deductions under both s.36(1)(vii) and s.36(1)(viia)(c), holding the proviso to s.36(1)(vii) merely caps bad-debt write-offs by the credit balance in provisions to prevent double deduction; factual review showed no excess or duplication, so CIT(A)'s allowance was upheld. On s.14A, the Tribunal directed the AO to confine disallowance to the assessee's suo-motu pro-rata allocation to investment-department costs, rejecting the AO's challenge absent specific contrary accounting findings. Deductions under s.36(1)(viii) were held independent of s.36(1)(viia)(c) computations. The amortised rent issue was remitted to the AO for reconsideration under s.158A upon Form-8 compliance.
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