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...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
