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...
Where a taxpayer had diligently pursued rectification within time and filed the statutory challenge within three months of its rejection, the HC held that limitation could not be computed only from the original assessment order. The appellate authority should not have rejected the challenge as time-barred in those circumstances, and if the absence of a specific challenge to the rectification rejection was treated as a defect, amendment ought to have been permitted instead of dismissal on a hyper-technical ground. The limitation-based rejection was set aside and the matter remitted for fresh decision on merits.
Where a taxpayer had diligently pursued rectification within time and filed the statutory challenge within three months of its rejection, the HC held that limitation could not be computed only from the original assessment order. The appellate authority should not have rejected the challenge as time-barred in those circumstances, and if the absence of a specific challenge to the rectification rejection was treated as a defect, amendment ought to have been permitted instead of dismissal on a hyper-technical ground. The limitation-based rejection was set aside and the matter remitted for fresh decision on merits.
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