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...
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
Note: It is a system-generated summary and is for quick reference only.
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