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...
Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.
Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.
Note: It is a system-generated summary and is for quick reference only.
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