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...
Inordinate delay of about 11 years was not condoned because a vague explanation based on ignorance of tax procedure, wrong advice and change of consultant did not show sufficient cause for the entire period; the appeal was therefore time-barred and not examined on merits. On the double taxation issue, the Tribunal accepted that the surrendered income in AY 2010-11 appeared to have been taxed again in reopened earlier years, applied the rule that the same income can be taxed only once, and directed deletion of the addition subject to verification that the amounts were identical.
Inordinate delay of about 11 years was not condoned because a vague explanation based on ignorance of tax procedure, wrong advice and change of consultant did not show sufficient cause for the entire period; the appeal was therefore time-barred and not examined on merits. On the double taxation issue, the Tribunal accepted that the surrendered income in AY 2010-11 appeared to have been taxed again in reopened earlier years, applied the rule that the same income can be taxed only once, and directed deletion of the addition subject to verification that the amounts were identical.
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