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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Adjustment of interest and penalty from the refundable amount - Such power of adjustment cannot be exercised for demand of tax/interest/penalty which is sub judice. Admittedly, in the facts of the present case, the amount of interest and penalty are sub judice before this Tribunal and this fact was admittedly in the knowledge of the court below. - the adjustment made from the amount refundable to the appellant is bad and the same is set aside. - AT
Adjustment of interest and penalty from the refundable amount - Such power of adjustment cannot be exercised for demand of tax/interest/penalty which is sub judice. Admittedly, in the facts of the present case, the amount of interest and penalty are sub judice before this Tribunal and this fact was admittedly in the knowledge of the court below. - the adjustment made from the amount refundable to the appellant is bad and the same is set aside. - AT
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