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...
Direction of CIT(A) u/s 150 to take remedial action u/s 148 - Section 150(2) provides that direction shall not apply to an assessment year which was the subject matter of the appeal and limiting was already expired - as per section 149(1)(b), notice u/s 148 could have issued by the end of assessment year 2015-16 which had already elapsed - non est direction
Direction of CIT(A) u/s 150 to take remedial action u/s 148 - Section 150(2) provides that direction shall not apply to an assessment year which was the subject matter of the appeal and limiting was already expired - as per section 149(1)(b), notice u/s 148 could have issued by the end of assessment year 2015-16 which had already elapsed - non est direction
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