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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Penalty u/s 271D - contravention of provisions of 269SS - Scope of 'reasonable cause' used in Section 273B - Even though transactions of one party had been settled by the other party by way of assignment of receivables / payables or for any other reason as detailed supra, we find that all the transactions have been ultimately settled for the difference amount by account payee cheques only. - No penalty - AT
Penalty u/s 271D - contravention of provisions of 269SS - Scope of 'reasonable cause' used in Section 273B - Even though transactions of one party had been settled by the other party by way of assignment of receivables / payables or for any other reason as detailed supra, we find that all the transactions have been ultimately settled for the difference amount by account payee cheques only. - No penalty - AT
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