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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Validity of the reassessment proceeding framed u/s 147 - Admittedly, the addition on account of bogus purchases has been made by the AO which is sufficient enough for initiating the proceedings under section 147 of the Act - initiation of the proceedings cannot be held invalid merely on the reasoning that there was no addition made by the AO on account of freight expenses though there was the mention of such expenses in the reasons recorded. - AT
Validity of the reassessment proceeding framed u/s 147 - Admittedly, the addition on account of bogus purchases has been made by the AO which is sufficient enough for initiating the proceedings under section 147 of the Act - initiation of the proceedings cannot be held invalid merely on the reasoning that there was no addition made by the AO on account of freight expenses though there was the mention of such expenses in the reasons recorded. - AT
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