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...
Power of CIT(A) to enhance the assessment - It is pertinent to note that requirement of issuing show cause notice is must prior to enhancement of the assessment as envisaged in Section 251(2) of the Act for each and every enhancement and it does not depend on overall outcome of the total income of the assessee in pursuant to the order of the ld. CIT(A) - Merely because some additions made by the AO are deleted by the CIT(A), the requirement of issuing notice for new additions cannot be escaped - AT
Power of CIT(A) to enhance the assessment - It is pertinent to note that requirement of issuing show cause notice is must prior to enhancement of the assessment as envisaged in Section 251(2) of the Act for each and every enhancement and it does not depend on overall outcome of the total income of the assessee in pursuant to the order of the ld. CIT(A) - Merely because some additions made by the AO are deleted by the CIT(A), the requirement of issuing notice for new additions cannot be escaped - AT
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