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...
Section 153C jurisdiction for assessment years beyond the six preceding years requires the Assessing Officer to record satisfaction that escaped income is represented by an asset. The six-year period is reckoned from the assessment year relevant to the previous year in which seized material is received by the Assessing Officer having jurisdiction over the other person; on that basis, AY 2015-16 fell within the extended period. However, a satisfaction note referring only to alleged cash transactions did not establish the mandatory asset-representation condition. The assessment was therefore treated as void for lack of valid jurisdiction, and the consequential addition could not survive; issues concerning digital evidence, consolidated satisfaction and merits remained open.
Section 153C jurisdiction for assessment years beyond the six preceding years requires the Assessing Officer to record satisfaction that escaped income is represented by an asset. The six-year period is reckoned from the assessment year relevant to the previous year in which seized material is received by the Assessing Officer having jurisdiction over the other person; on that basis, AY 2015-16 fell within the extended period. However, a satisfaction note referring only to alleged cash transactions did not establish the mandatory asset-representation condition. The assessment was therefore treated as void for lack of valid jurisdiction, and the consequential addition could not survive; issues concerning digital evidence, consolidated satisfaction and merits remained open.
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