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...
Levy of penalty u/s.271(1)(c) - defective notice - it would be too technical and pedantic to take the view that because in the printed notice the inapplicable portion was not struck off, the order of penalty should be set aside even though in the assessment order it was clearly mentioned that penalty proceedings u/s 271(1)(c) of the Act had been initiated separately for furnishing inaccurate particulars of income. - However penalty deleted since the assessee had declared the full facts.
Levy of penalty u/s.271(1)(c) - defective notice - it would be too technical and pedantic to take the view that because in the printed notice the inapplicable portion was not struck off, the order of penalty should be set aside even though in the assessment order it was clearly mentioned that penalty proceedings u/s 271(1)(c) of the Act had been initiated separately for furnishing inaccurate particulars of income. - However penalty deleted since the assessee had declared the full facts.
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