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...
Cash receipts and repayments between an assessee and close family members, including related family entities, were not treated as loans or deposits under the relevant cash transaction provisions. The Tribunal noted that the family relationship was undisputed and applied the Gujarat High Court ratio in Dr. Rajaram L. Akhani to hold that such intra-family transactions do not fall within the mischief of the cash loan and deposit restrictions. As the statutory foundation for penalty failed, the penalties for cash acceptance and cash repayment were unsustainable and were deleted; both appeals were allowed.
Cash receipts and repayments between an assessee and close family members, including related family entities, were not treated as loans or deposits under the relevant cash transaction provisions. The Tribunal noted that the family relationship was undisputed and applied the Gujarat High Court ratio in Dr. Rajaram L. Akhani to hold that such intra-family transactions do not fall within the mischief of the cash loan and deposit restrictions. As the statutory foundation for penalty failed, the penalties for cash acceptance and cash repayment were unsustainable and were deleted; both appeals were allowed.
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