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...
Penalty under section 271AAB requires undisclosed income as exhaustively defined in its Explanation; a surrender made during a search does not alone establish that statutory character. Land and other advances represent application or outflow of funds rather than an unrecorded income inflow, and deeming provisions for unexplained investments cannot be automatically applied to this self-contained penal provision. Uncorroborated diary notings without verifiable particulars cannot independently prove real transactions or undisclosed income. As the amount was accepted as current-year business income without a requisite finding of undisclosed income, deletion of the penalty on the surrendered advances was sustained.
Penalty under section 271AAB requires undisclosed income as exhaustively defined in its Explanation; a surrender made during a search does not alone establish that statutory character. Land and other advances represent application or outflow of funds rather than an unrecorded income inflow, and deeming provisions for unexplained investments cannot be automatically applied to this self-contained penal provision. Uncorroborated diary notings without verifiable particulars cannot independently prove real transactions or undisclosed income. As the amount was accepted as current-year business income without a requisite finding of undisclosed income, deletion of the penalty on the surrendered advances was sustained.
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