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 u/s 271(1)(c) - wrong claim of set off loss - explanation was not found false - no iota of evidence of concealment of any fact relating to particulars of income or furnishing of inaccurate particulars of income - Merely because the assessee had claimed the expenditure, which was not accepted or was not acceptable to the revenue, that by itself would not, attract the penalty u/s 271(1)(c)
Penalty u/s 271(1)(c) - wrong claim of set off loss - explanation was not found false - no iota of evidence of concealment of any fact relating to particulars of income or furnishing of inaccurate particulars of income - Merely because the assessee had claimed the expenditure, which was not accepted or was not acceptable to the revenue, that by itself would not, attract the penalty u/s 271(1)(c)
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