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...
Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.
Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.
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