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 - AO doubted the credit worthiness - It is not a case where the ld. CIT(A) has not given an opportunity to the AO to rebut the submissions made before him. In this view of the matter and in view of the detailed discussion made by the ld. CIT(A) while deleting the addition on account of share application money and unsecured loan in respect of different investors as mentioned earlier, the same, in our opinion, does not call for any interference and, accordingly, the same is upheld. - AT
Addition u/s 68 - AO doubted the credit worthiness - It is not a case where the ld. CIT(A) has not given an opportunity to the AO to rebut the submissions made before him. In this view of the matter and in view of the detailed discussion made by the ld. CIT(A) while deleting the addition on account of share application money and unsecured loan in respect of different investors as mentioned earlier, the same, in our opinion, does not call for any interference and, accordingly, the same is upheld. - AT
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