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...
Revision u/s 263 - Validity of order of ITAT, cancelling the order of assessment u/s 115 WE(3) and directing the assessing officer to make an order de novo only for the reason that there is no discussion in the order or in the record of the assessment proceedings - Tribunal confirming the order passed by the Commissioner of Income Tax u/s 263 - it is evident that the Tribunal has not considered the claim of the assessee with regard to fringe benefits under Section 115WE of the Act on merits - Matter restored back to ITAT - HC
Revision u/s 263 - Validity of order of ITAT, cancelling the order of assessment u/s 115 WE(3) and directing the assessing officer to make an order de novo only for the reason that there is no discussion in the order or in the record of the assessment proceedings - Tribunal confirming the order passed by the Commissioner of Income Tax u/s 263 - it is evident that the Tribunal has not considered the claim of the assessee with regard to fringe benefits under Section 115WE of the Act on merits - Matter restored back to ITAT - HC
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