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...
Addition u/s 69C - Unexplained expenses/premium - assessee did not furnish the source of payment of such expenses/premium - The case of assessee throughout the proceedings was that she is not having sufficient income. The expenses incurred by the other co-owners on her behalf and that no such similar addition was made in case of other co-owners, on whose behalf similar expenses were incurred by other co-owners. - It is settled law that the assessee cannot be treated as indifferently in respect of expenses or treatment of capital gain. - Additions deleted - AT
Addition u/s 69C - Unexplained expenses/premium - assessee did not furnish the source of payment of such expenses/premium - The case of assessee throughout the proceedings was that she is not having sufficient income. The expenses incurred by the other co-owners on her behalf and that no such similar addition was made in case of other co-owners, on whose behalf similar expenses were incurred by other co-owners. - It is settled law that the assessee cannot be treated as indifferently in respect of expenses or treatment of capital gain. - Additions deleted - AT
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