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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Revision u/s 263 - cash expenditure , prior period expenses, provisions for incentive etc. - CIT has not exercised jurisdiction u/s 263 on the ground of ‘no enquiry’ or ‘lack of enquiry’ made by the AO but on conclusions drawn by the AO in allowing expenditure set out in the SCN u/s 263 ought not to have been allowed as deduction - jurisdiction validly invoked
Revision u/s 263 - cash expenditure , prior period expenses, provisions for incentive etc. - CIT has not exercised jurisdiction u/s 263 on the ground of ‘no enquiry’ or ‘lack of enquiry’ made by the AO but on conclusions drawn by the AO in allowing expenditure set out in the SCN u/s 263 ought not to have been allowed as deduction - jurisdiction validly invoked
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