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...
Validity of order u/s 92CA - time limit for passing of the TPO order - period of limitation - despite the fact that the reference made to the Ld. TPO is valid, in absence of a legally valid transfer pricing order and a valid draft assessment order, the Ld. AO cannot assume jurisdiction to proceed with the assessment under Section 144C of the Act and pass the consequential final assessment order. - the final assessment order passed is beyond the prescribed period of limitation u/s 153 - AT
Validity of order u/s 92CA - time limit for passing of the TPO order - period of limitation - despite the fact that the reference made to the Ld. TPO is valid, in absence of a legally valid transfer pricing order and a valid draft assessment order, the Ld. AO cannot assume jurisdiction to proceed with the assessment under Section 144C of the Act and pass the consequential final assessment order. - the final assessment order passed is beyond the prescribed period of limitation u/s 153 - AT
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