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...
Penalty u/s 271(1)(c) - bonafide belief - interest income earned during the year on fixed deposits and savings bank accounts were not offered to tax - Assessee contended that, the TDS figure and the corresponding income relating to second, third and fourth quarter of the relevant financial year were made available on the 26AS site only in September, 2017 by ICICI Bank. The aforesaid explanation of the assessee appears to be believable in view of the certificate issued by the concerned bank on 28th April, 2018. - there was reasonable cause in terms with section 274 - AT
Penalty u/s 271(1)(c) - bonafide belief - interest income earned during the year on fixed deposits and savings bank accounts were not offered to tax - Assessee contended that, the TDS figure and the corresponding income relating to second, third and fourth quarter of the relevant financial year were made available on the 26AS site only in September, 2017 by ICICI Bank. The aforesaid explanation of the assessee appears to be believable in view of the certificate issued by the concerned bank on 28th April, 2018. - there was reasonable cause in terms with section 274 - AT
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