Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
A return filed in response to a notice under section 148, when filed within the period specified in that notice, is treated under section 148(2) as a return furnished under section 139. Read together, sections 148 and 80AC permit a deduction claim where the reassessment return is timely, notwithstanding that no original return was filed under section 139(1). The text also explains that revision under section 263 is not warranted where the assessment record shows that the deduction claim was examined and allowed after application of mind; the assessment order must be both erroneous and prejudicial to Revenue interests.
A return filed in response to a notice under section 148, when filed within the period specified in that notice, is treated under section 148(2) as a return furnished under section 139. Read together, sections 148 and 80AC permit a deduction claim where the reassessment return is timely, notwithstanding that no original return was filed under section 139(1). The text also explains that revision under section 263 is not warranted where the assessment record shows that the deduction claim was examined and allowed after application of mind; the assessment order must be both erroneous and prejudicial to Revenue interests.
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