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 ITAT considered the validity of an order u/s 143(1)(a) where the AO made adjustments based on the tax auditor's entry for penalty or fine. The AO communicated the proposed adjustment and provided reasons in the intimation order. The ITAT referenced the distinction between intimation and assessment per the Supreme Court's ruling in CIT Vs Rajesh Jhaveri Stock Brokers P ltd. The AO's authority is limited to adjustments based on the return of income, not debatable issues. In this case, the AO's actions were deemed appropriate as the adjustment was based on a prima facie disallowable amount categorized by the tax auditor. The appeal was allowed for statistical purposes. The decision aligns with legal principles governing adjustments u/s 143(1)(a).
The ITAT considered the validity of an order u/s 143(1)(a) where the AO made adjustments based on the tax auditor's entry for penalty or fine. The AO communicated the proposed adjustment and provided reasons in the intimation order. The ITAT referenced the distinction between intimation and assessment per the Supreme Court's ruling in CIT Vs Rajesh Jhaveri Stock Brokers P ltd. The AO's authority is limited to adjustments based on the return of income, not debatable issues. In this case, the AO's actions were deemed appropriate as the adjustment was based on a prima facie disallowable amount categorized by the tax auditor. The appeal was allowed for statistical purposes. The decision aligns with legal principles governing adjustments u/s 143(1)(a).
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