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) - Since the assessee had furnished full particulars about the expenditure incurred including non–deduction of TDS in the tax audit report itself, it cannot be accused of furnishing inaccurate particulars of income - failure to disallow the amount u/s 40(a)(ia) was due to a bona fide mistake is acceptable - penalty deleted
Penalty u/s 271(1)(c) - Since the assessee had furnished full particulars about the expenditure incurred including non–deduction of TDS in the tax audit report itself, it cannot be accused of furnishing inaccurate particulars of income - failure to disallow the amount u/s 40(a)(ia) was due to a bona fide mistake is acceptable - penalty deleted
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