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...
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Reopening of assessment u/s 147 - change of opinion - mechanical satisfaction - Admission of additional income by Senior Executive of the petitioner during the search - variation in additional income admitted - The High Court upheld the justification for reopening provided by the respondents, highlighting the availability of fresh material and alleged failures by the petitioners to fully disclose material evidence. Objections regarding change of opinion and mechanical satisfaction were rejected.
Reopening of assessment u/s 147 - change of opinion - mechanical satisfaction - Admission of additional income by Senior Executive of the petitioner during the search - variation in additional income admitted - The High Court upheld the justification for reopening provided by the respondents, highlighting the availability of fresh material and alleged failures by the petitioners to fully disclose material evidence. Objections regarding change of opinion and mechanical satisfaction were rejected.
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