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...
Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.
Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.
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