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...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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HC upheld revision under s.263 regarding treatment of provision for doubtful debts in computing book profits under s.115-JB. AO's acceptance of assessee's claim was mechanical, without examining why provision for doubtful assets was claimed as deduction despite not being debited to provision account. Amount was merely shown as reduction from trade receivables for disclosure, not as written-off debts. Assessee maintained recovery hopes. PCIT's jurisdiction exercise directing re-examination was justified. Tribunal correctly analyzed legal position, finding no illegality in CIT's order. HC found no jurisdictional infirmity, ruling against assessee's appeal.
HC upheld revision under s.263 regarding treatment of provision for doubtful debts in computing book profits under s.115-JB. AO's acceptance of assessee's claim was mechanical, without examining why provision for doubtful assets was claimed as deduction despite not being debited to provision account. Amount was merely shown as reduction from trade receivables for disclosure, not as written-off debts. Assessee maintained recovery hopes. PCIT's jurisdiction exercise directing re-examination was justified. Tribunal correctly analyzed legal position, finding no illegality in CIT's order. HC found no jurisdictional infirmity, ruling against assessee's appeal.
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