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...
Revision u/s 263 - debatable issue - taxability of interest received by the Assessee on the enhanced compensation u/s 28 of the Land Acquisition Act - The Appellate Tribunal examined the issues raised and found that the initiation of proceedings under section 263 lacked merit, as the order passed under section 154 of the Act rectifying the mistake apparent from the record was valid. Moreover, the Tribunal recognized the debatable nature of the taxability issue and emphasized that when two plausible views exist, the jurisdictional PCIT cannot assume jurisdiction under section 263 of the Act.
Revision u/s 263 - debatable issue - taxability of interest received by the Assessee on the enhanced compensation u/s 28 of the Land Acquisition Act - The Appellate Tribunal examined the issues raised and found that the initiation of proceedings under section 263 lacked merit, as the order passed under section 154 of the Act rectifying the mistake apparent from the record was valid. Moreover, the Tribunal recognized the debatable nature of the taxability issue and emphasized that when two plausible views exist, the jurisdictional PCIT cannot assume jurisdiction under section 263 of the Act.
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