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 - PCIT observed that AO had failed to examine and verify the issues related to share premium received and interest earned, which issues had remained unaddressed - The action of the Ld. PCIT is in direct contravention of the provisions of Explanation (a)(i) to section 56(2)(vii) of the I.T. Act read with rule 11UA(2)(b) of the I.T. Rules. - AO could not have changed the method of valuation opted by the Assessee - Revision order quashed - AT
Revision u/s 263 - PCIT observed that AO had failed to examine and verify the issues related to share premium received and interest earned, which issues had remained unaddressed - The action of the Ld. PCIT is in direct contravention of the provisions of Explanation (a)(i) to section 56(2)(vii) of the I.T. Act read with rule 11UA(2)(b) of the I.T. Rules. - AO could not have changed the method of valuation opted by the Assessee - Revision order quashed - AT
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