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...
Addition u/s 68 / 69C - unverified/non-existent /bogus sundry creditors - Assessee also cannot get scot free by not producing the sundry creditors and making purchases from parties who are not maintaining proper records or who have made adverse statements and, therefore, the assessee cannot be equated with another assessee who is maintaining records meticulously and not making purchase from grey market. - adoption of GP rate of 16% on such unsubstantiated purchases from the six creditors will meet the ends of justice. - AT
Addition u/s 68 / 69C - unverified/non-existent /bogus sundry creditors - Assessee also cannot get scot free by not producing the sundry creditors and making purchases from parties who are not maintaining proper records or who have made adverse statements and, therefore, the assessee cannot be equated with another assessee who is maintaining records meticulously and not making purchase from grey market. - adoption of GP rate of 16% on such unsubstantiated purchases from the six creditors will meet the ends of justice. - AT
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