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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Deduction u/s 10AA - Disallowance for the reason that the assessee had filed return of income belatedly and not within the time limit prescribed u/s 139(1) - When the Legislature has omitted such a restriction in section 10AA in its wisdom, it is not for the A.O. nor the CIT(A) to prescribe such a conditionality and impose it on an assessee. - AT
Deduction u/s 10AA - Disallowance for the reason that the assessee had filed return of income belatedly and not within the time limit prescribed u/s 139(1) - When the Legislature has omitted such a restriction in section 10AA in its wisdom, it is not for the A.O. nor the CIT(A) to prescribe such a conditionality and impose it on an assessee. - AT
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