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 a revision u/s 263 where the Commissioner held that the expenditure claimed by the assessee for payment to sub-contractors was not genuine. The AO had conducted an inquiry and accepted the claim based on relevant material. The work order served as tangible evidence of the agreement between parties. The Commissioner's doubts were based on suspicion, while the AO's decision was reasonable. The AO's inquiry, even if inadequate, did not render the order erroneous. The Commissioner cannot revise based solely on disagreement. The impugned order was set aside as unsustainable. The assessee's appeal was allowed.
The Appellate Tribunal considered a case involving a revision u/s 263 where the Commissioner held that the expenditure claimed by the assessee for payment to sub-contractors was not genuine. The AO had conducted an inquiry and accepted the claim based on relevant material. The work order served as tangible evidence of the agreement between parties. The Commissioner's doubts were based on suspicion, while the AO's decision was reasonable. The AO's inquiry, even if inadequate, did not render the order erroneous. The Commissioner cannot revise based solely on disagreement. The impugned order was set aside as unsustainable. The assessee's appeal was allowed.
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