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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Revision u/s 263 - As per CIT AO has not called for any details to ascertain the amount and nature of total remittances received by the assessee during the year - various inconsistencies in the approach of learned CIT gives an impression that he himself was not sure about the nature and character of shipping income earned by the assessee. - CIT was not justified in assuming jurisdiction u/s 263 - AT
Revision u/s 263 - As per CIT AO has not called for any details to ascertain the amount and nature of total remittances received by the assessee during the year - various inconsistencies in the approach of learned CIT gives an impression that he himself was not sure about the nature and character of shipping income earned by the assessee. - CIT was not justified in assuming jurisdiction u/s 263 - AT
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