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...
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Reopening of assessment before expiry of 4 years - no sufficient reason to believe - Merely because reopening of assessment was before expiry of four years from the end of the relevant assessment year, that by itself will not give licence to the AO to exercise his powers u/s 147 with impunity even in the absence or lack of fresh tangible material coming to his possession - AT
Reopening of assessment before expiry of 4 years - no sufficient reason to believe - Merely because reopening of assessment was before expiry of four years from the end of the relevant assessment year, that by itself will not give licence to the AO to exercise his powers u/s 147 with impunity even in the absence or lack of fresh tangible material coming to his possession - AT
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