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 made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
Assessment u/s 153A - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
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