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...
Penalty for failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.
Penalty for failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.
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