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...
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Revision u/s 263 - Addition u/s 68 - there is no material on record to demonstrate the source of funds so infused by way of share capital in the assessee company. The Assessing officer has merely relied on the statement of the assessee company that the shares have been allotted to the respective shareholders and in support, only the name of the shareholders and respective amount invested by them have been submitted. - the order so passed by the AO is clearly erroneous and prejudicial to the interest of Revenue. - AT
Revision u/s 263 - Addition u/s 68 - there is no material on record to demonstrate the source of funds so infused by way of share capital in the assessee company. The Assessing officer has merely relied on the statement of the assessee company that the shares have been allotted to the respective shareholders and in support, only the name of the shareholders and respective amount invested by them have been submitted. - the order so passed by the AO is clearly erroneous and prejudicial to the interest of Revenue. - AT
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