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...
Constitutional validity - Section 80A(5) bars and prohibits the assessee from claiming the deduction u/s 10A and 10B and Chapter VIA if no such claim was made in the return of income. It is also mandatory that the return of income for claiming such deduction should be filed within the time stipulated u/s 139 (1) - The amendment made cannot be faulted and quashed on the ground that it was discriminatory, arbitrary, unreasonable and violative of Article 14 - However, amendment or correction in the claim allowed.
Constitutional validity - Section 80A(5) bars and prohibits the assessee from claiming the deduction u/s 10A and 10B and Chapter VIA if no such claim was made in the return of income. It is also mandatory that the return of income for claiming such deduction should be filed within the time stipulated u/s 139 (1) - The amendment made cannot be faulted and quashed on the ground that it was discriminatory, arbitrary, unreasonable and violative of Article 14 - However, amendment or correction in the claim allowed.
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