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...
Validity of Proceeding u/s 158BC - satisfaction was not recorded before completion of assessment proceeding - the order passed by the AO as well as the CIT (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Apex Court.
Validity of Proceeding u/s 158BC - satisfaction was not recorded before completion of assessment proceeding - the order passed by the AO as well as the CIT (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Apex Court.
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