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...
Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.
Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.
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