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...
An appellate authority dealing with one assessment year cannot issue directions affecting reopening for earlier years, because its jurisdiction is confined to the year under appeal. The Tribunal held that the Commissioner (Appeals) went beyond the scope of the appeal by directing reopening of earlier assessment years, so that direction was beyond competence and had to be expunged. The separate validity of reopening under section 150 was left unexamined, as the matter was resolved on lack of appellate jurisdiction alone.
An appellate authority dealing with one assessment year cannot issue directions affecting reopening for earlier years, because its jurisdiction is confined to the year under appeal. The Tribunal held that the Commissioner (Appeals) went beyond the scope of the appeal by directing reopening of earlier assessment years, so that direction was beyond competence and had to be expunged. The separate validity of reopening under section 150 was left unexamined, as the matter was resolved on lack of appellate jurisdiction alone.
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