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...
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
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