HC upholds rulings on foreign commission, market losses, liquidated damages, Section 14A disallowance, and patent charges

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The HC upheld the Tribunal's findings on multiple issues, ruling largely against the revenue. Foreign commission payments without supporting evidence were held not taxable in India, consistent with established precedent and statutory provisions limiting income deemed to accrue in India. Market-to-market losses on forward contracts were not disallowed, reaffirming the AO's independence against CBDT instructions. Liquidated damages received for delayed delivery of capital assets were classified as capital receipts, not business income. Disallowance under Section 14A read with Rule 8D was sustained, as the assessee accounted for all investments capable of yielding exempt income. Advances written off to farmers required no interference, alignin.........