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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Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
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