Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Mandatory pre-show cause intimation under Rule 142(1)(A) was not issued before initiation of the assessment proceedings, and that fact was undisputed. Applying the earlier Division Bench ruling on the same point, the HC held that such non-compliance vitiates the assessment order and requires it to be set aside. The impugned assessment for the relevant financial year was accordingly quashed, and the matter was remanded for fresh assessment in accordance with law, subject to deposit of 20% of the disputed tax within the time granted.
Mandatory pre-show cause intimation under Rule 142(1)(A) was not issued before initiation of the assessment proceedings, and that fact was undisputed. Applying the earlier Division Bench ruling on the same point, the HC held that such non-compliance vitiates the assessment order and requires it to be set aside. The impugned assessment for the relevant financial year was accordingly quashed, and the matter was remanded for fresh assessment in accordance with law, subject to deposit of 20% of the disputed tax within the time granted.
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