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...
Addition u/s 69A r.w.s. 115BBE - Assessment of trust - ‘unexplained money' - Income consists of voluntary contributions from devotees and followers - The High Court held that, ITAT having accepted Petitioner’s plea that for the assessment year in question, Petitioner’s total income should be computed as ‘Nil’, the only task before the AO was to issue refund to Petitioner of all taxes paid or recovered from Petitioner for AY 2017-2018. Since before the Hon’ble ITAT there was no controversy as regards the date of filing of return by Petitioner or Form 10B, the AO cannot, in the garb of giving effect to the order of ITAT, initiate a new controversy.
Addition u/s 69A r.w.s. 115BBE - Assessment of trust - ‘unexplained money' - Income consists of voluntary contributions from devotees and followers - The High Court held that, ITAT having accepted Petitioner’s plea that for the assessment year in question, Petitioner’s total income should be computed as ‘Nil’, the only task before the AO was to issue refund to Petitioner of all taxes paid or recovered from Petitioner for AY 2017-2018. Since before the Hon’ble ITAT there was no controversy as regards the date of filing of return by Petitioner or Form 10B, the AO cannot, in the garb of giving effect to the order of ITAT, initiate a new controversy.
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