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...
Change of opinion precludes reassessment of share-capital and investment transactions already examined through detailed scrutiny, where the assessee neither concealed nor withheld material; an anonymous complaint alone cannot reopen those matters. Reassessment notices converted into show-cause notices under the amended regime must be issued within the surviving limitation period after excluding the stay period and response time. Extended limitation cannot apply unless the statutory conditions are invoked and recorded, and sanction is obtained from the competent authority where the relevant period has elapsed. A notice issued beyond the surviving period is void, rendering consequential reassessment, demand and penalty actions unsustainable, subject to fresh proceedings where legally permissible.
Change of opinion precludes reassessment of share-capital and investment transactions already examined through detailed scrutiny, where the assessee neither concealed nor withheld material; an anonymous complaint alone cannot reopen those matters. Reassessment notices converted into show-cause notices under the amended regime must be issued within the surviving limitation period after excluding the stay period and response time. Extended limitation cannot apply unless the statutory conditions are invoked and recorded, and sanction is obtained from the competent authority where the relevant period has elapsed. A notice issued beyond the surviving period is void, rendering consequential reassessment, demand and penalty actions unsustainable, subject to fresh proceedings where legally permissible.
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