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...
Treatment of interest deduction under Income from Other Sources: an inadmissible claim of interest deduction that neutralises disclosed interest income and is not substantiated attracts penalty under the penalty regime for under reporting of income. Principle of consistency was held inapplicable where earlier returns were processed under summary intimation and no scrutiny assessment was carried out, because such intimation does not preclude re examination. Immunity clauses for bona fide explanations or estimation do not apply where the assessee fails to disclose all material facts, specifically the nexus between funds borrowed and loans given; on that factual failure the assessing officer's disallowance and consequent penalty were sustained.
Treatment of interest deduction under Income from Other Sources: an inadmissible claim of interest deduction that neutralises disclosed interest income and is not substantiated attracts penalty under the penalty regime for under reporting of income. Principle of consistency was held inapplicable where earlier returns were processed under summary intimation and no scrutiny assessment was carried out, because such intimation does not preclude re examination. Immunity clauses for bona fide explanations or estimation do not apply where the assessee fails to disclose all material facts, specifically the nexus between funds borrowed and loans given; on that factual failure the assessing officer's disallowance and consequent penalty were sustained.
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