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 - Addl. CIT who has given approval for such reopening has simply mentioned that “ yes, I am satisfied that this is a fit case for issue notice of u/s 148 of I.T. Act”. A perusal of the approval given by the Addl. CIT shows that he has not applied his mind properly and has in a mechanical manner given his approval - Reassessment proceedings initiated by the AO are not as per law and has to be quashed. - AT
Reopening of assessment u/s 147 - Addl. CIT who has given approval for such reopening has simply mentioned that “ yes, I am satisfied that this is a fit case for issue notice of u/s 148 of I.T. Act”. A perusal of the approval given by the Addl. CIT shows that he has not applied his mind properly and has in a mechanical manner given his approval - Reassessment proceedings initiated by the AO are not as per law and has to be quashed. - AT
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