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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The ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
The ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
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