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...
Undisclosed income of the assessee - Unexplained NRI gifts - onus to prove - Had the appellant given a convincing and believable explanation / reply to the respondent, the question of charging additional tax would not have arisen. That apart, no gifts would be extended to a person after receipt of commission by the donors and the exchange of gifts must be warmhearted and not out of compulsion or demand. - HC
Undisclosed income of the assessee - Unexplained NRI gifts - onus to prove - Had the appellant given a convincing and believable explanation / reply to the respondent, the question of charging additional tax would not have arisen. That apart, no gifts would be extended to a person after receipt of commission by the donors and the exchange of gifts must be warmhearted and not out of compulsion or demand. - HC
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