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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Unexplained expenditure u/s 69C - genuineness of purchases - Assessee statedly had made purchases from the three parties - Payments made through banking channels - Assessee in our view has discharged his onus in respect of the subject purchases. AO has also not doubted the sales arising out of the said export activity and its GPR. This is not a case which falls within the ambit of Section 69C as held by the AO. - HC
Unexplained expenditure u/s 69C - genuineness of purchases - Assessee statedly had made purchases from the three parties - Payments made through banking channels - Assessee in our view has discharged his onus in respect of the subject purchases. AO has also not doubted the sales arising out of the said export activity and its GPR. This is not a case which falls within the ambit of Section 69C as held by the AO. - HC
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