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...
Scope of prima facie adjustment u/s 143(1) by CPC - debatable issue - In this very case, although in one year the same amount was treated as stipend exempt u/s 10(16) of the Act and in year two said amount was treated to be taxable income. Hence, issue was not simple but a debatable one - Revenue was clearly in error in making aforesaid adjustments. - AT
Scope of prima facie adjustment u/s 143(1) by CPC - debatable issue - In this very case, although in one year the same amount was treated as stipend exempt u/s 10(16) of the Act and in year two said amount was treated to be taxable income. Hence, issue was not simple but a debatable one - Revenue was clearly in error in making aforesaid adjustments. - AT
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