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...
Rectification u/s 154 - No doubt that the income tax authority can rectify any apparent mistake in its order however, when the order of the AO, has been upheld by the ld.CIT(A) and thereafter by the Tribunal, in that eventuality, AO is denuded from rectifying any such mistake, as it would lead to giving unbridled power to AO/ ld.CIT(A) to unsettled the settled position of fact and law and will lead to chaos and anarchy. - There cannot be two contradictory orders of the Tribunal one by upholding the assessment and other quashing the assessment based on the jurisdictional error. - orders of CIT appeals - reversed decided in favour of revenue - AT
Rectification u/s 154 - No doubt that the income tax authority can rectify any apparent mistake in its order however, when the order of the AO, has been upheld by the ld.CIT(A) and thereafter by the Tribunal, in that eventuality, AO is denuded from rectifying any such mistake, as it would lead to giving unbridled power to AO/ ld.CIT(A) to unsettled the settled position of fact and law and will lead to chaos and anarchy. - There cannot be two contradictory orders of the Tribunal one by upholding the assessment and other quashing the assessment based on the jurisdictional error. - orders of CIT appeals - reversed decided in favour of revenue - AT
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