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...
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
