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...
The ITAT Ahmedabad held that a best judgment assessment u/s 144 without issuing notice u/s 143(2) is invalid if the assessee has filed a return and responded to AO's notice. Courts emphasize Section 144 is for non-compliance cases. Assessee provided details of cash deposits, supported by affidavits from relatives. Deposits were found to be from maturity proceeds, not unexplained money u/s 69A. Addition in brother's hands linked to joint account. CIT(A) erred in upholding half of assessment u/s 69A. Affidavits, if credible, can explain cash source. Lack of concrete reasons to reject explanations. Entire u/s 69A addition deleted, penalty proceedings u/s 271AAC(1) & 271F dropped. Assessee's appeal allowed.
The ITAT Ahmedabad held that a best judgment assessment u/s 144 without issuing notice u/s 143(2) is invalid if the assessee has filed a return and responded to AO's notice. Courts emphasize Section 144 is for non-compliance cases. Assessee provided details of cash deposits, supported by affidavits from relatives. Deposits were found to be from maturity proceeds, not unexplained money u/s 69A. Addition in brother's hands linked to joint account. CIT(A) erred in upholding half of assessment u/s 69A. Affidavits, if credible, can explain cash source. Lack of concrete reasons to reject explanations. Entire u/s 69A addition deleted, penalty proceedings u/s 271AAC(1) & 271F dropped. Assessee's appeal allowed.
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