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...
Under the post-1.4.2021 reassessment scheme, notice under section 148 can be issued where the Assessing Officer has material indicating escapement of income, and the sufficiency of incriminating material is tested in reassessment, not at the notice stage; the reopening was therefore upheld. The Tribunal also held that section 170 governs successor liability on amalgamation and that absence of pending proceedings on the amalgamation date did not invalidate action against the successor. On merits, additions treating sale proceeds of earlier-year investments as unexplained cash credit, and related commission for alleged accommodation entries, were deleted because the transactions were supported by banking records, the investments had earlier been accepted, and reliance on third-party statements without cross-examination violated natural justice.
Under the post-1.4.2021 reassessment scheme, notice under section 148 can be issued where the Assessing Officer has material indicating escapement of income, and the sufficiency of incriminating material is tested in reassessment, not at the notice stage; the reopening was therefore upheld. The Tribunal also held that section 170 governs successor liability on amalgamation and that absence of pending proceedings on the amalgamation date did not invalidate action against the successor. On merits, additions treating sale proceeds of earlier-year investments as unexplained cash credit, and related commission for alleged accommodation entries, were deleted because the transactions were supported by banking records, the investments had earlier been accepted, and reliance on third-party statements without cross-examination violated natural justice.
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