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 search-linked reassessment under the post-01.04.2021 regime, a search, a post-assessment statement, and field verification were treated as fresh tangible material supporting a reasoned belief of escapement; the challenge based on change of opinion and absence of incriminating material was rejected. For the unexplained cash credit issue, the Tribunal found that the Revenue relied substantially on an adverse third-party statement that was uncorroborated, while the assessee was denied cross-examination, amounting to a serious breach of natural justice. It also noted that Section 68 applies only to credits received in the relevant year, not opening balances, and remitted the additions for fresh adjudication after cross-examination and proper inquiry.
In search-linked reassessment under the post-01.04.2021 regime, a search, a post-assessment statement, and field verification were treated as fresh tangible material supporting a reasoned belief of escapement; the challenge based on change of opinion and absence of incriminating material was rejected. For the unexplained cash credit issue, the Tribunal found that the Revenue relied substantially on an adverse third-party statement that was uncorroborated, while the assessee was denied cross-examination, amounting to a serious breach of natural justice. It also noted that Section 68 applies only to credits received in the relevant year, not opening balances, and remitted the additions for fresh adjudication after cross-examination and proper inquiry.
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