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...
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
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