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...
Rectification u/s 154 - additional depreciation @20% claimed as per provision of Sec. 32(1)(iia) - it is on record of the AO that the issue is debatable and the issue which has been rectified by the AO u/s 154 is highly debatable and it is the settled legal preposition of law that a debatable issue cannot be rectified u/s 154 and cannot be said mistake apparent on record.
Rectification u/s 154 - additional depreciation @20% claimed as per provision of Sec. 32(1)(iia) - it is on record of the AO that the issue is debatable and the issue which has been rectified by the AO u/s 154 is highly debatable and it is the settled legal preposition of law that a debatable issue cannot be rectified u/s 154 and cannot be said mistake apparent on record.
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