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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Imposition of penalty - discrepancy in Form 31 - certain columns were left blank - only carrying of Form 31 has been prescribed but there is no mention that all column should be duly filled and even from the facts on record it is abundantly clear that there was no intention to evade tax and therefore the penalty order which has been issued is clearly arbitrary and liable to be set aside
Imposition of penalty - discrepancy in Form 31 - certain columns were left blank - only carrying of Form 31 has been prescribed but there is no mention that all column should be duly filled and even from the facts on record it is abundantly clear that there was no intention to evade tax and therefore the penalty order which has been issued is clearly arbitrary and liable to be set aside
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