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...
Deduction u/s. 80JJAA - claim made was disallowed to the assessee because it was not included in the return of income filed by the assessee - Assessee did not have the opportunity to raise the contention before the AO as its return was processed by CPC, Bangalore and intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is completed. The claim made by the assessee at the first appellate stage is an allowable claim. - AT
Deduction u/s. 80JJAA - claim made was disallowed to the assessee because it was not included in the return of income filed by the assessee - Assessee did not have the opportunity to raise the contention before the AO as its return was processed by CPC, Bangalore and intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is completed. The claim made by the assessee at the first appellate stage is an allowable claim. - AT
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