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...
A reassessment order cannot be revised under section 263 merely because the Principal Commissioner believes further inquiry was desirable, where the Assessing Officer had examined the recorded reasons issue, considered contract notes, bank statements, computation and audited accounts, and accepted the assessee's explanation. The Tribunal held that Explanation 2 to section 263 does not apply absent a finding that the reassessment was made without any enquiry or verification. The reassessment was therefore not erroneous or prejudicial to the interests of the revenue, and the revisional jurisdiction was wrongly assumed; the revision order was quashed.
A reassessment order cannot be revised under section 263 merely because the Principal Commissioner believes further inquiry was desirable, where the Assessing Officer had examined the recorded reasons issue, considered contract notes, bank statements, computation and audited accounts, and accepted the assessee's explanation. The Tribunal held that Explanation 2 to section 263 does not apply absent a finding that the reassessment was made without any enquiry or verification. The reassessment was therefore not erroneous or prejudicial to the interests of the revenue, and the revisional jurisdiction was wrongly assumed; the revision order was quashed.
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