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...
Reopening of assessment u/s 147 - Validity of a notice issued u/s 148 - The petitioner had not disclosed the amount of reimbursement of expenses claimed by it and the actual amount received by it towards reimbursement. It had not submitted the details of expenses incurred by it for verification during the assessment proceedings. It did not produce any ledger, bills and vouchers of expenses incurred on behalf of the Principal Companies. Thus the petitioner did not make a “full and true” disclosure of all the material facts which resulted in an income having escaped assessment. - Review petition dismissed - HC
Reopening of assessment u/s 147 - Validity of a notice issued u/s 148 - The petitioner had not disclosed the amount of reimbursement of expenses claimed by it and the actual amount received by it towards reimbursement. It had not submitted the details of expenses incurred by it for verification during the assessment proceedings. It did not produce any ledger, bills and vouchers of expenses incurred on behalf of the Principal Companies. Thus the petitioner did not make a “full and true” disclosure of all the material facts which resulted in an income having escaped assessment. - Review petition dismissed - HC
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