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...
Addition u/s 68 - unexplained deposits in Dubai bank account - CIT(A) has observed that taxability of sum in Dubai Bank account is beyond the jurisdiction of Indian tax authorities as the assessee is an NRI. Once it is clear and accepted by the Assessing Officer also that sums were sent to India from assessee’s (an NRI) foreign bank account in Dubai the provisions of DTAA are attracted. Hence, the reasoning of the learned CIT(A) that sum in Dubai bank account are subject matter of taxation in Dubai and not in India is correct. - AT
Addition u/s 68 - unexplained deposits in Dubai bank account - CIT(A) has observed that taxability of sum in Dubai Bank account is beyond the jurisdiction of Indian tax authorities as the assessee is an NRI. Once it is clear and accepted by the Assessing Officer also that sums were sent to India from assessee’s (an NRI) foreign bank account in Dubai the provisions of DTAA are attracted. Hence, the reasoning of the learned CIT(A) that sum in Dubai bank account are subject matter of taxation in Dubai and not in India is correct. - AT
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