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...
Jurisdiction of Commissioner (Appeals) to issue fresh Show Cause Noice (SCN) or to raise demand on new ground - The power to issue a notice is specifically provided for in section 73(1) of the Finance Act. Once it is specifically so provided, it cannot be urged that this power to issue the notice would also be available under sub-section (4) of section 85 of the Finance Act to a Commissioner (Appeals) when he is hearing an appeal, merely because of the use of the expression 'pass such orders, as he thinks fit'. - AT
Jurisdiction of Commissioner (Appeals) to issue fresh Show Cause Noice (SCN) or to raise demand on new ground - The power to issue a notice is specifically provided for in section 73(1) of the Finance Act. Once it is specifically so provided, it cannot be urged that this power to issue the notice would also be available under sub-section (4) of section 85 of the Finance Act to a Commissioner (Appeals) when he is hearing an appeal, merely because of the use of the expression 'pass such orders, as he thinks fit'. - AT
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