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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
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