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 - non-deduction of TDS on freight - failure to furnish Form 26Q - A perusal of the file of the ld. Pr. CIT reveals an “Office Note” appended to the assessment order - The same unequivocally confirms that no inquiry on the aspect raised by the ld. Pr. CIT, i.e., the cumulative satisfaction of the conditions of ss. 194C(6) & 194C(7), as against s. 194C(6) alone, qua which only the AO has limited his inquiry and issued his finding, had been made in assessment. - revision order sustained - AT
Revision u/s 263 - non-deduction of TDS on freight - failure to furnish Form 26Q - A perusal of the file of the ld. Pr. CIT reveals an “Office Note” appended to the assessment order - The same unequivocally confirms that no inquiry on the aspect raised by the ld. Pr. CIT, i.e., the cumulative satisfaction of the conditions of ss. 194C(6) & 194C(7), as against s. 194C(6) alone, qua which only the AO has limited his inquiry and issued his finding, had been made in assessment. - revision order sustained - AT
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