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...
Revision u/s 263 - Genuineness of expenditure (Commission paid) - The ITAT found that the commission agreement was genuine, payments were made through banking channels, and tax was deducted at source, supporting the legitimacy of the transaction. Despite the substantial amount of commission paid, the ITAT emphasized that the genuineness of the transaction should be verified, which was found to be in order. The discrepancy in GST calculations and reported figures was deemed irrelevant by the ITAT. - The ITAT allowed the appeal of the assessee, quashing the order passed by the Ld. Pr. CIT under Section 263.
Revision u/s 263 - Genuineness of expenditure (Commission paid) - The ITAT found that the commission agreement was genuine, payments were made through banking channels, and tax was deducted at source, supporting the legitimacy of the transaction. Despite the substantial amount of commission paid, the ITAT emphasized that the genuineness of the transaction should be verified, which was found to be in order. The discrepancy in GST calculations and reported figures was deemed irrelevant by the ITAT. - The ITAT allowed the appeal of the assessee, quashing the order passed by the Ld. Pr. CIT under Section 263.
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