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 - Change of opinion - TP adjustment addition - Courts have repeatedly held that once a query is raised and that has been explained by the assessee, even if there is no discussion on that aspect in the assessment order still the Assessing Officer is deemed to have consider these points and applied his mind. - All these only indicate one thing that re-opening is proposed on the basis of change of opinion. - HC
Reopening of assessment u/s 147 - Change of opinion - TP adjustment addition - Courts have repeatedly held that once a query is raised and that has been explained by the assessee, even if there is no discussion on that aspect in the assessment order still the Assessing Officer is deemed to have consider these points and applied his mind. - All these only indicate one thing that re-opening is proposed on the basis of change of opinion. - HC
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