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 Income Tax Appellate Tribunal allowed the assessee's appeal for statistical purposes. It set aside the CIT(A)'s dismissal of the rectification application and directed the CIT(A) to decide the grounds of appeal raised by the assessee on merits as per Section 250(6) of the Act. The Tribunal held that the CIT(A)'s action of not interfering with the CPC's adjustment regarding GST/CENVAT refund on the ground of requiring verification of books of accounts was akin to "missing the woods for trees". The Tribunal emphasized that rules of procedure should promote justice, not obstruct it, relying on the Supreme Court's observation in MV Vali Perov. Fernandeo Lopez case.
The Income Tax Appellate Tribunal allowed the assessee's appeal for statistical purposes. It set aside the CIT(A)'s dismissal of the rectification application and directed the CIT(A) to decide the grounds of appeal raised by the assessee on merits as per Section 250(6) of the Act. The Tribunal held that the CIT(A)'s action of not interfering with the CPC's adjustment regarding GST/CENVAT refund on the ground of requiring verification of books of accounts was akin to "missing the woods for trees". The Tribunal emphasized that rules of procedure should promote justice, not obstruct it, relying on the Supreme Court's observation in MV Vali Perov. Fernandeo Lopez case.
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