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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Condonation of delay in filing of appeal before CIT (A) - In the case in hands, the branch has to act as per advice of Head Office, hence, which consumed sufficient period of time, therefore, it could not be regarded as negligence or of lacking of bona-fides. We are of the considered opinion that CIT (A) was not justified in refusing to condone the delay in filing of appeal - Delay condoned.
Condonation of delay in filing of appeal before CIT (A) - In the case in hands, the branch has to act as per advice of Head Office, hence, which consumed sufficient period of time, therefore, it could not be regarded as negligence or of lacking of bona-fides. We are of the considered opinion that CIT (A) was not justified in refusing to condone the delay in filing of appeal - Delay condoned.
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