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...
Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible
Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible
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