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...
Uncorroborated retracted search statements, third-party tally data and WhatsApp material were found insufficient to sustain alleged commission additions in the individual assessee's case, because there was no cash trail, bank entry or independent documentary proof of receipt; the additions were deleted. Reassessment notices issued beyond three years were held invalid where section 149(1)(b) was not satisfied, as the alleged escapement did not meet the Rs. 50 lakh threshold; the reassessment proceedings were quashed. In the company's case, alleged cash-sales and commission-expenditure issues were remanded for fresh adjudication because factual verification and 65B compliance were required.
Uncorroborated retracted search statements, third-party tally data and WhatsApp material were found insufficient to sustain alleged commission additions in the individual assessee's case, because there was no cash trail, bank entry or independent documentary proof of receipt; the additions were deleted. Reassessment notices issued beyond three years were held invalid where section 149(1)(b) was not satisfied, as the alleged escapement did not meet the Rs. 50 lakh threshold; the reassessment proceedings were quashed. In the company's case, alleged cash-sales and commission-expenditure issues were remanded for fresh adjudication because factual verification and 65B compliance were required.
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