https://www.taxtmi.com/caselaws?id=207552 The Court upheld the Tribunal's decision that the liability relating to royalty and extension fee had crystalized during the relevant year, allowing the deduction claimed by the H.P. Forest Corporation for the assessment year 1995-96. The Court emphasized that the revenue could not introduce new arguments at the appeal stage, particularly regarding the nature of the payment as tax or business expenditure. The appeal was dismissed, affirming the Tribunal's ruling on the crystalization of liability and rejecting the revenue's attempt to raise new issues during the appeal process. en-us Fri, 08 Jan 2010 00:00:00 +0530 Fri, 16 Dec 2011 08:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207552 The Court upheld the Tribunal's decision that the liability relating to royalty and extension fee had crystalized during the relevant year, allowing the deduction claimed by the H.P. Forest Corporation for the assessment year 1995-96. The Court emphasized that the revenue could not introduce new arguments at the appeal stage, particularly regarding the nature of the payment as tax or business expenditure. The appeal was dismissed, affirming the Tribunal's ruling on the crystalization of liability and rejecting the revenue's attempt to raise new issues during the appeal process. Case-Laws Income Tax Fri, 08 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207552