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...
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Petitioner's NRO account deposits were subject to TDS deduction; transferred shares from deceased wife's account not taxable. Respondents classified petitioner as resident, demanded tax on deposits as unexplained investments and transferred shares as purchase of securities. Petitioner unable to explain due to wife's demise and personal commitments. Order passed without opportunity of hearing, violating natural justice. Order set aside, matter remanded for fresh consideration after allowing petitioner to file reply/objections and personal hearing.
Petitioner's NRO account deposits were subject to TDS deduction; transferred shares from deceased wife's account not taxable. Respondents classified petitioner as resident, demanded tax on deposits as unexplained investments and transferred shares as purchase of securities. Petitioner unable to explain due to wife's demise and personal commitments. Order passed without opportunity of hearing, violating natural justice. Order set aside, matter remanded for fresh consideration after allowing petitioner to file reply/objections and personal hearing.
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