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...
Prosecution Proceedings initiated u/s 276C - Bogus LTCG - guilty mind i.e., mens rea - willful evasion of tax on claims made under the head LTCG/Short Term Capital Loss - The mere fact of not accurate tax, not exact tax or erroneous tax would not lead to the proceedings under Section 276 of the Act. - The petitioners revised their tax filings and paid the necessary taxes after the discrepancies were pointed out (post search and seizure), indicating a lack of mens rea. Consequently, the proceedings against them u/s 276C were quashed. - HC
Prosecution Proceedings initiated u/s 276C - Bogus LTCG - guilty mind i.e., mens rea - willful evasion of tax on claims made under the head LTCG/Short Term Capital Loss - The mere fact of not accurate tax, not exact tax or erroneous tax would not lead to the proceedings under Section 276 of the Act. - The petitioners revised their tax filings and paid the necessary taxes after the discrepancies were pointed out (post search and seizure), indicating a lack of mens rea. Consequently, the proceedings against them u/s 276C were quashed. - HC
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