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 Appellate Tribunal considered a case involving revision u/s 263 of the Act related to annuity payments made to LIC. The employer did not make the annuity payment; it was made on employees' request from VRS amount. The claim for exemption u/s 10(10CC) and u/s 10(10BB) was found incorrect as per PCIT's enquiry. AO allowed exemptions without verifying from the employer, leading to an erroneous order. The annuity amount paid to LIC was deemed taxable as salary per Supreme Court ruling. The AO's failure to conduct proper inquiries rendered the order prejudicial to revenue. Jurisdiction u/s 263 was upheld, dismissing the assessee's appeals.
The Appellate Tribunal considered a case involving revision u/s 263 of the Act related to annuity payments made to LIC. The employer did not make the annuity payment; it was made on employees' request from VRS amount. The claim for exemption u/s 10(10CC) and u/s 10(10BB) was found incorrect as per PCIT's enquiry. AO allowed exemptions without verifying from the employer, leading to an erroneous order. The annuity amount paid to LIC was deemed taxable as salary per Supreme Court ruling. The AO's failure to conduct proper inquiries rendered the order prejudicial to revenue. Jurisdiction u/s 263 was upheld, dismissing the assessee's appeals.
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