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...
Revision u/s 263 by CIT - no discussion or elaborate discussion in the assessment order - It is for the Tax Authorities to ensure that the Assessing Officers are well instructed to write the order elaborating the issues enquired into; the evidences considered to allow the claim and also discussions on how the claim is rejected. The assessee has no role to play as how the assessment orders are written. - AT
Revision u/s 263 by CIT - no discussion or elaborate discussion in the assessment order - It is for the Tax Authorities to ensure that the Assessing Officers are well instructed to write the order elaborating the issues enquired into; the evidences considered to allow the claim and also discussions on how the claim is rejected. The assessee has no role to play as how the assessment orders are written. - AT
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