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...
Rectification u/s 154 - non deduction of TDS u/s 194I - The Tribunal examined the rectification proceedings and found that the Assessing Officer's actions were not sustainable in law. Despite previous rectifications in favor of the assessee, the AO pursued further rectification, incorrectly asserting TDS liabilities. The Tribunal held that such rectification, involving detailed inquiries, was not permissible under legal precedent. Therefore, the lower authorities erred in treating the assessee as the assessee-in-default under section 201, and the rectification was deemed not sustainable.
Rectification u/s 154 - non deduction of TDS u/s 194I - The Tribunal examined the rectification proceedings and found that the Assessing Officer's actions were not sustainable in law. Despite previous rectifications in favor of the assessee, the AO pursued further rectification, incorrectly asserting TDS liabilities. The Tribunal held that such rectification, involving detailed inquiries, was not permissible under legal precedent. Therefore, the lower authorities erred in treating the assessee as the assessee-in-default under section 201, and the rectification was deemed not sustainable.
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