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...
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Revision u/s 263 - the notice u/s. 143(2) of the Act, was issued much prior to the assessee filing his return of income. This is not in accordance with law. Hence the order passed u/s. 148 of the Act without issuing valid notice u/s. 143(2) of the Act, makes the reassessment order dt. 20/05/2016, passed u/s. 143(3)/147 of the Act, bad in law - Consequently, the revision of the assessment u/s. 263, revising such illegal assessment order is also bad in law. - AT
Revision u/s 263 - the notice u/s. 143(2) of the Act, was issued much prior to the assessee filing his return of income. This is not in accordance with law. Hence the order passed u/s. 148 of the Act without issuing valid notice u/s. 143(2) of the Act, makes the reassessment order dt. 20/05/2016, passed u/s. 143(3)/147 of the Act, bad in law - Consequently, the revision of the assessment u/s. 263, revising such illegal assessment order is also bad in law. - AT
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