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...
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
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