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...
Application of Section 14A r.w.rule 8D - whereas in the earlier years AO did not make any disallowance - While it is true that the principle of res judicata would not apply to assessment proceedings under the Act, the need for consistency and certainty and existence of strong and compelling reasons for a departure from a settled position has to be spelt out which conspicuously is absent in the present case - SC
Application of Section 14A r.w.rule 8D - whereas in the earlier years AO did not make any disallowance - While it is true that the principle of res judicata would not apply to assessment proceedings under the Act, the need for consistency and certainty and existence of strong and compelling reasons for a departure from a settled position has to be spelt out which conspicuously is absent in the present case - SC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
