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 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
Section 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
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