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...
An ex parte revision order under section 263 was held unsustainable because the assessee received only one day to respond to the show-cause notice, which was treated as denial of a reasonable opportunity of hearing and a breach of audi alteram partem. By majority, the Tribunal held that the defect was procedural and curable, so the revision proceedings were not terminated; the impugned order was set aside and the matter remanded for fresh adjudication after adequate opportunity, uninfluenced by observations on merits.
An ex parte revision order under section 263 was held unsustainable because the assessee received only one day to respond to the show-cause notice, which was treated as denial of a reasonable opportunity of hearing and a breach of audi alteram partem. By majority, the Tribunal held that the defect was procedural and curable, so the revision proceedings were not terminated; the impugned order was set aside and the matter remanded for fresh adjudication after adequate opportunity, uninfluenced by observations on merits.
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