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...
Rectification u/s 254 - Assessment proceedings u/s 158BC - jurisdiction questioned by the assessee with reference to Section 158BD - it is the Tribunal which has committed error in restricting itself to legal ground and in not addressing itself on certain other grounds of substantial nature without any fault attributable to the assessee. In such a situation, the cause of substantial justice deserves to be preferred over the technical considerations pitted against it by way of limitation, to shun an apparent miscarriage of justice. - Remedy sought by the assessee can not be frustrated on the grounds of bar of limitation without weighing the circumstances of the case. - AT
Rectification u/s 254 - Assessment proceedings u/s 158BC - jurisdiction questioned by the assessee with reference to Section 158BD - it is the Tribunal which has committed error in restricting itself to legal ground and in not addressing itself on certain other grounds of substantial nature without any fault attributable to the assessee. In such a situation, the cause of substantial justice deserves to be preferred over the technical considerations pitted against it by way of limitation, to shun an apparent miscarriage of justice. - Remedy sought by the assessee can not be frustrated on the grounds of bar of limitation without weighing the circumstances of the case. - AT
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