Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
Special insurance income computation preserves statutory deductions while limiting transfer-pricing, withholding and disallowance adjustments for gene...
Termination compensation under a distribution arrangement that is substantively an agency relationship is treated as business income rather than a capital receipt, and taxation is confined to the settlement actually received. A non-compete covenant integral to acquiring and protecting a trademark qualifies as a depreciable intangible asset. For section 80-IB, only costs directly connected with an eligible undertaking should reduce its profit; allocation of finance, research, travel, head-office and export-promotion costs depends on factual nexus. Section 80HHC excludes receipts lacking a direct export nexus, while concurrent 80-IB and 80HHC deductions remain subject to the gross-total-income ceiling. A purely legal additional ground based on the existing record may be considered.
Termination compensation under a distribution arrangement that is substantively an agency relationship is treated as business income rather than a capital receipt, and taxation is confined to the settlement actually received. A non-compete covenant integral to acquiring and protecting a trademark qualifies as a depreciable intangible asset. For section 80-IB, only costs directly connected with an eligible undertaking should reduce its profit; allocation of finance, research, travel, head-office and export-promotion costs depends on factual nexus. Section 80HHC excludes receipts lacking a direct export nexus, while concurrent 80-IB and 80HHC deductions remain subject to the gross-total-income ceiling. A purely legal additional ground based on the existing record may be considered.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
