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...
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
