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...
Validity of reassessment order - actual suppression of turnover - if an inspection is not conducted in the business premises of the petitioner, the sales suppression could not have come to light. In such event, the third respondent is wholly justified in imposing double the sale suppressed amount in the revised assessment proceedings together with 150% of penalty. The appellate authority as well as the Tribunal have also dealt with this aspect and refused to accede to the plea of the petitioner. - HC
Validity of reassessment order - actual suppression of turnover - if an inspection is not conducted in the business premises of the petitioner, the sales suppression could not have come to light. In such event, the third respondent is wholly justified in imposing double the sale suppressed amount in the revised assessment proceedings together with 150% of penalty. The appellate authority as well as the Tribunal have also dealt with this aspect and refused to accede to the plea of the petitioner. - HC
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