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...
Addition u/s 68 - unexplained share application money - The Tribunal noted that the assessee provided complete details of the share subscribers, their financial capacity, and the transactions were carried out through banking channels, shifting the burden of proof to the Assessing Officer (AO) who failed to conduct an adequate inquiry to disprove the assessee's claims. Therefore, the primary onus placed on the assessee by section 68 was discharged, and the addition made by the AO was not justified.
Addition u/s 68 - unexplained share application money - The Tribunal noted that the assessee provided complete details of the share subscribers, their financial capacity, and the transactions were carried out through banking channels, shifting the burden of proof to the Assessing Officer (AO) who failed to conduct an adequate inquiry to disprove the assessee's claims. Therefore, the primary onus placed on the assessee by section 68 was discharged, and the addition made by the AO was not justified.
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