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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Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
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