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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Rectification of mistake - in absence of any assessment order issued by him there existed no basis to invoke the power of rectification u/s 31, by the assessing authority. Consequently, the assessing authority never acquired any jurisdiction to issue any notice or pass any order of rectification - The entire exercise carried by the assessing authority was a nullity and it must therefore necessarily fall.
Rectification of mistake - in absence of any assessment order issued by him there existed no basis to invoke the power of rectification u/s 31, by the assessing authority. Consequently, the assessing authority never acquired any jurisdiction to issue any notice or pass any order of rectification - The entire exercise carried by the assessing authority was a nullity and it must therefore necessarily fall.
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