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...
Section 264 provides beneficial and remedial revisional relief against over-assessment, including errors in a taxpayer's return. Relief is not dependent on filing a revised return within the prescribed time or on whether the error arose from the taxpayer's voluntary action or a departmental order. Taxing the same income in two assessment years can create an over-assessment where the combined effect of the relevant orders results in double taxation. A revisional authority must examine the claim and reconciliations on their merits rather than reject relief solely because an intimation accepted the returned income in isolation.
Section 264 provides beneficial and remedial revisional relief against over-assessment, including errors in a taxpayer's return. Relief is not dependent on filing a revised return within the prescribed time or on whether the error arose from the taxpayer's voluntary action or a departmental order. Taxing the same income in two assessment years can create an over-assessment where the combined effect of the relevant orders results in double taxation. A revisional authority must examine the claim and reconciliations on their merits rather than reject relief solely because an intimation accepted the returned income in isolation.
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