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...
Reopening of assessment u/s 147 - Unexplained loan - There were no justification for the A.O. to record non-existing, incorrect and wrong facts in the reasons for reopening of the assessment.The entirety of the facts clearly show that A.O. recorded wrong, incorrect and non-existing reasons for reopening of the assessment without application of mind and such reopening of the assessment would be invalid and bad in Law. - AT
Reopening of assessment u/s 147 - Unexplained loan - There were no justification for the A.O. to record non-existing, incorrect and wrong facts in the reasons for reopening of the assessment.The entirety of the facts clearly show that A.O. recorded wrong, incorrect and non-existing reasons for reopening of the assessment without application of mind and such reopening of the assessment would be invalid and bad in Law. - AT
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