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...
Remittances received by an NRE account holder from non-resident relatives through banking channels, where NRE status and compliance with RBI guidelines are undisputed, were treated as exempt income not includible in total income. Funds credited to NRE accounts were regarded as beyond tax authorities' reach regarding their foreign source. Applying prior High Court rulings, the Tribunal's deletion of additions for unexplained investment and unexplained cash credits under sections 69 and 68 was sustained, and the Revenue's challenge was rejected because no substantial question of law arose.
Remittances received by an NRE account holder from non-resident relatives through banking channels, where NRE status and compliance with RBI guidelines are undisputed, were treated as exempt income not includible in total income. Funds credited to NRE accounts were regarded as beyond tax authorities' reach regarding their foreign source. Applying prior High Court rulings, the Tribunal's deletion of additions for unexplained investment and unexplained cash credits under sections 69 and 68 was sustained, and the Revenue's challenge was rejected because no substantial question of law arose.
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