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...
ITAT remanded the case to the Addl./Joint CIT(A) to determine the validity of an adjustment under section 143(1)(a) without a prior show cause notice. The tribunal found potential procedural irregularities in the tax assessment, specifically questioning whether a mandatory notice was issued before making the adjustment. The appellate authority was directed to ascertain the factual circumstances, particularly examining whether the absence of a show cause notice renders the tax adjustment invalid. The assessee's appeal was allowed for statistical purposes, with instructions to comprehensively review the procedural compliance and potential exemption allowability based on the audit report filing.
ITAT remanded the case to the Addl./Joint CIT(A) to determine the validity of an adjustment under section 143(1)(a) without a prior show cause notice. The tribunal found potential procedural irregularities in the tax assessment, specifically questioning whether a mandatory notice was issued before making the adjustment. The appellate authority was directed to ascertain the factual circumstances, particularly examining whether the absence of a show cause notice renders the tax adjustment invalid. The assessee's appeal was allowed for statistical purposes, with instructions to comprehensively review the procedural compliance and potential exemption allowability based on the audit report filing.
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