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...
Revision u/s 263 - disallowance u/s 40(a)(ia) - CIT has not correctly interpreted the provisions of sec.194C(2) nor consider the law amended in sec.40(a)(ia) held to be applicable retrospectively - CIT also failed to verify and conduct the minimal enquiry about non-deduction of TDS and deposit of TDS before the due date for filing the return of income - Revision order set aside.
Revision u/s 263 - disallowance u/s 40(a)(ia) - CIT has not correctly interpreted the provisions of sec.194C(2) nor consider the law amended in sec.40(a)(ia) held to be applicable retrospectively - CIT also failed to verify and conduct the minimal enquiry about non-deduction of TDS and deposit of TDS before the due date for filing the return of income - Revision order set aside.
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