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2003 (3) TMI 87 - BOMBAY HIGH COURT
Royalty - Special Deduction - Whether the value of work-in-progress should be treated as part of capital employed for the purposes of section 80J of the Income-tax Act, 1961, and secondly, whether deduction under section 80-O should be calculated on the gross fees received by the assessee. – this question is answered in negative, i.e., in favour of the Department and against the assessee.