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...
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
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