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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Penalty u/s 271 (1)(c) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
Penalty u/s 271 (1)(c) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
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