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...
Power of CIT for enhancement u/s 251 - those items, which were not part of the ROI, Assessment proceedings or Assessment order, cannot be considered by the ld CIT (A) for enhancement. Right course would have been to intimate ld AO to issue notice u/s 148 of the Act or to propose revision u/s 263 of the Act. - AT
Power of CIT for enhancement u/s 251 - those items, which were not part of the ROI, Assessment proceedings or Assessment order, cannot be considered by the ld CIT (A) for enhancement. Right course would have been to intimate ld AO to issue notice u/s 148 of the Act or to propose revision u/s 263 of the Act. - AT
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