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...
In an abated search assessment under section 153A, the return filed in response to the search notice substituted the earlier return, so the assessee could make a fresh or altered claim and the Revenue could not apply reassessment principles; the lease rentals from the IT park/SEZ were accepted as business income in line with the CBDT circular and past departmental acceptance. On disallowance under section 14A, the Tribunal sustained restriction of the disallowance under normal provisions to exempt income and upheld that section 14A read with Rule 8D could not be mechanically applied for book profit computation, subject to direct expenditure. The notional annual letting value of unsold stock-in-trade was deleted because section 23(5) operated only prospectively from assessment year 2018-19.
In an abated search assessment under section 153A, the return filed in response to the search notice substituted the earlier return, so the assessee could make a fresh or altered claim and the Revenue could not apply reassessment principles; the lease rentals from the IT park/SEZ were accepted as business income in line with the CBDT circular and past departmental acceptance. On disallowance under section 14A, the Tribunal sustained restriction of the disallowance under normal provisions to exempt income and upheld that section 14A read with Rule 8D could not be mechanically applied for book profit computation, subject to direct expenditure. The notional annual letting value of unsold stock-in-trade was deleted because section 23(5) operated only prospectively from assessment year 2018-19.
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