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...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
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