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...
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Reopening of assessment u/s 147 - eligibility of reasons to believe - the sole basis for the AO to form reasonable belief of escapement of income is, Tax Audit Report filed by the assessee along with return of income, which was very much available with the AO, when he had completed assessment proceedings u/s.143(3) of the Act. - notice issued by the AO u/s.148 of the Act, and consequent assessment proceedings u/s.147 of the Act, are bad in law - AT
Reopening of assessment u/s 147 - eligibility of reasons to believe - the sole basis for the AO to form reasonable belief of escapement of income is, Tax Audit Report filed by the assessee along with return of income, which was very much available with the AO, when he had completed assessment proceedings u/s.143(3) of the Act. - notice issued by the AO u/s.148 of the Act, and consequent assessment proceedings u/s.147 of the Act, are bad in law - AT
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