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...
The Delhi High Court considered the addition u/s 68 and the evidentiary value of statements recorded u/s 132(4). The court emphasized that an assessment cannot be based solely on presumptions or statements without corroborating material. While statements are considered information, they must be supported by evidence found during a search for assessment. The court also discussed rectification u/s 292B, stating that jurisdictional defects cannot be cured under this section, rendering proceedings void. In this case, the Revenue failed to link seized material to the assessee group, leading to the assessment being set aside in favor of the assessee by the ITAT.
The Delhi High Court considered the addition u/s 68 and the evidentiary value of statements recorded u/s 132(4). The court emphasized that an assessment cannot be based solely on presumptions or statements without corroborating material. While statements are considered information, they must be supported by evidence found during a search for assessment. The court also discussed rectification u/s 292B, stating that jurisdictional defects cannot be cured under this section, rendering proceedings void. In this case, the Revenue failed to link seized material to the assessee group, leading to the assessment being set aside in favor of the assessee by the ITAT.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
