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...
Reopening of assessment u/s 147 - Reason to believe - the AO had disallowed some of the expenses which had been reflected in the break-up under the head “details of advertisement and sales promotion expenses” while passing the final order of assessment, which reflects that the AO had applied its mind to the appellant’s claim while passing the order under section 143(3) - reasons do not disclose as to what material or fact was not disclosed by the assessee. - HC
Reopening of assessment u/s 147 - Reason to believe - the AO had disallowed some of the expenses which had been reflected in the break-up under the head “details of advertisement and sales promotion expenses” while passing the final order of assessment, which reflects that the AO had applied its mind to the appellant’s claim while passing the order under section 143(3) - reasons do not disclose as to what material or fact was not disclosed by the assessee. - HC
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