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...
Penalty u/s 271B - Determination of turnover of the assessee for Tax Audit u/s 44AB - turnover in respect of the speculative transactions shall be positive and negative differences of the transactions and not volume of the speculative transactions. Accordingly in view of the consist view taken by this Tribunal the turnover of the assessee would not exceed the limit as provide d U/s 44AB, the penalty levied U/s 271B is deleted
Penalty u/s 271B - Determination of turnover of the assessee for Tax Audit u/s 44AB - turnover in respect of the speculative transactions shall be positive and negative differences of the transactions and not volume of the speculative transactions. Accordingly in view of the consist view taken by this Tribunal the turnover of the assessee would not exceed the limit as provide d U/s 44AB, the penalty levied U/s 271B is deleted
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