https://www.taxtmi.com/caselaws?id=796515 Deductibility of a genuine compensatory patent-settlement payment is examined under section 37(1), with the payment characterised as revenue expenditure where it resolves foreign patent litigation, protects business interests, and involves no proven guilt or prohibited purpose under the applicable law. Related financing interest is treated as consequential to the settlement's allowability. The material also addresses transfer-pricing treatment of captive-power transfers and associated-enterprise transactions; the cap on section 14A disallowance at exempt income and exclusion from book-profit computation; business-promotion expenditure; foreign-tax credit verification; research-and-development deductions; and wealth-tax provisions in book-profit computation. Software expenditure remains capital where depreciation has been claimed and allowed. en-us Fri, 31 Jul 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796515 Deductibility of a genuine compensatory patent-settlement payment is examined under section 37(1), with the payment characterised as revenue expenditure where it resolves foreign patent litigation, protects business interests, and involves no proven guilt or prohibited purpose under the applicable law. Related financing interest is treated as consequential to the settlement's allowability. The material also addresses transfer-pricing treatment of captive-power transfers and associated-enterprise transactions; the cap on section 14A disallowance at exempt income and exclusion from book-profit computation; business-promotion expenditure; foreign-tax credit verification; research-and-development deductions; and wealth-tax provisions in book-profit computation. Software expenditure remains capital where depreciation has been claimed and allowed. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796515