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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The Supreme Court dismissed the appeal and concurred with the Delhi High Court's interpretation of Section 271AAA(2) of the Income Tax Act, 1961. The assessee had declared a surrendered amount as "additional income," which was accepted by the Revenue. However, the assessee failed to substantiate the manner in which the undisclosed income was derived as required u/s 271AAA(2). Consequently, the lower appellate authorities erred in holding that the conditions in Section 271AAA(2) were satisfied by the assessee, and the penalty u/s 271AAA(1) was upheld.
The Supreme Court dismissed the appeal and concurred with the Delhi High Court's interpretation of Section 271AAA(2) of the Income Tax Act, 1961. The assessee had declared a surrendered amount as "additional income," which was accepted by the Revenue. However, the assessee failed to substantiate the manner in which the undisclosed income was derived as required u/s 271AAA(2). Consequently, the lower appellate authorities erred in holding that the conditions in Section 271AAA(2) were satisfied by the assessee, and the penalty u/s 271AAA(1) was upheld.
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