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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Revision u/s 263 by CIT - Merely on the basis of audit objection powers u/s 263 could not have been exercised. The impugned order u/s 263, does not indicate that the power was exercised on the basis of a finding of the assessment order being erroneous and prejudicial to the Revenue by examining facts and record by the ld. Revisional Authority beyond the audit objections - AT
Revision u/s 263 by CIT - Merely on the basis of audit objection powers u/s 263 could not have been exercised. The impugned order u/s 263, does not indicate that the power was exercised on the basis of a finding of the assessment order being erroneous and prejudicial to the Revenue by examining facts and record by the ld. Revisional Authority beyond the audit objections - AT
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