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...
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Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
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