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 271D - assessee had received the amounts in cash as loan from HUF - there cannot be any better reason for receipt of cash deposits than the death of Karta or Managing Director of the company. It is also not disputed that all the cash receipts were duly accounted in the books of the assesse as well as the HUF. There were no unaccounted transactions. - No penalty - AT
Levy of penalty u/s 271D - assessee had received the amounts in cash as loan from HUF - there cannot be any better reason for receipt of cash deposits than the death of Karta or Managing Director of the company. It is also not disputed that all the cash receipts were duly accounted in the books of the assesse as well as the HUF. There were no unaccounted transactions. - No penalty - AT
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