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...
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
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