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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Best judgment assessment u/s 144 - addition u/s 68 - The learned CIT(A) ought to have stepped into shoes of the AO to compute income chargeable to tax due to non co-operation of assessee in assessment - It was also incumbent on CIT(A) to have looked into applicability of provisions of Section 56(2)(viia) to transaction for purchase of equity shares - CIT(A) order set aside
Best judgment assessment u/s 144 - addition u/s 68 - The learned CIT(A) ought to have stepped into shoes of the AO to compute income chargeable to tax due to non co-operation of assessee in assessment - It was also incumbent on CIT(A) to have looked into applicability of provisions of Section 56(2)(viia) to transaction for purchase of equity shares - CIT(A) order set aside
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