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...
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Validity of assessment made u/s 147 instead of u/s. 153C - Addition as unexplained cash credit u/s. 68 - Upon examination, the ITAT Delhi found that the seized material, along with statements by involved parties, constituted incriminating evidence, warranting proceedings under section 153C. Citing precedent from various judicial decisions, the ITAT Delhi concluded that the failure to follow the procedure under section 153C invalidated the reassessment under section 147/148. Consequently, the ITAT Delhi upheld the decision of the CIT(A) to quash the reassessment.
Validity of assessment made u/s 147 instead of u/s. 153C - Addition as unexplained cash credit u/s. 68 - Upon examination, the ITAT Delhi found that the seized material, along with statements by involved parties, constituted incriminating evidence, warranting proceedings under section 153C. Citing precedent from various judicial decisions, the ITAT Delhi concluded that the failure to follow the procedure under section 153C invalidated the reassessment under section 147/148. Consequently, the ITAT Delhi upheld the decision of the CIT(A) to quash the reassessment.
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