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...
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Assessment u/s 153A - addition u/s 68 - The assessee contended that the additions were not based on any incriminating material found during the search. The Tribunal held that no addition could be made under Section 153A in the absence of incriminating material for the years where no assessment was pending. The court accepted this contention and deleted the additions. - The ITAT examined several additions and disallowances made by the assessing officer, including those related to cash deposits, unsecured loans, and depreciation on vehicles. In each instance, the court meticulously evaluated the submissions, documentary evidence, and legal positions before rendering its decisions, often in favor of the assessee by deleting unjustified additions.
Assessment u/s 153A - addition u/s 68 - The assessee contended that the additions were not based on any incriminating material found during the search. The Tribunal held that no addition could be made under Section 153A in the absence of incriminating material for the years where no assessment was pending. The court accepted this contention and deleted the additions. - The ITAT examined several additions and disallowances made by the assessing officer, including those related to cash deposits, unsecured loans, and depreciation on vehicles. In each instance, the court meticulously evaluated the submissions, documentary evidence, and legal positions before rendering its decisions, often in favor of the assessee by deleting unjustified additions.
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