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...
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
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