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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Reopening of assessment u/s 147 - additions u/s. 68 and u/s. 69C - Information from the Investigation Wing(Income-tax Department) can only trigger the reasons to suspect. Then the AO to make some preliminary inquiry and collect some material which would suggest the escapement of income - AO does not satisfy the jurisdictional requirement as per the settled law - Notice issued u/s 148 quashed.
Reopening of assessment u/s 147 - additions u/s. 68 and u/s. 69C - Information from the Investigation Wing(Income-tax Department) can only trigger the reasons to suspect. Then the AO to make some preliminary inquiry and collect some material which would suggest the escapement of income - AO does not satisfy the jurisdictional requirement as per the settled law - Notice issued u/s 148 quashed.
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