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...
Maintainability of wrt petition before HC where option for filing Revision u/s 264 is available - Rejection of Refund of excess amount paid as tax - There are no substance in the submission of the Petitioner that no revision would be available against the impugned order as it is not an order passed under the Act. Thus, remedy of revision u/s 264(1) would be available to the Petitioner.
Maintainability of wrt petition before HC where option for filing Revision u/s 264 is available - Rejection of Refund of excess amount paid as tax - There are no substance in the submission of the Petitioner that no revision would be available against the impugned order as it is not an order passed under the Act. Thus, remedy of revision u/s 264(1) would be available to the Petitioner.
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