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...
Addition u/s 56(2)(vii) r.w.s. 69 - difference between the purchase price i.e. circle rate/stamp duty value and the value determined by the DVO - This section can be invoked only if the circle rate of the property was more than the price at which the property was purchased and the property can be referred to DVO only if the assessee disputes the stamp duty value of the property. Thus, it is the plea of the assessee that invocation of section 56(2)(vii) is itself wrong. - AT
Addition u/s 56(2)(vii) r.w.s. 69 - difference between the purchase price i.e. circle rate/stamp duty value and the value determined by the DVO - This section can be invoked only if the circle rate of the property was more than the price at which the property was purchased and the property can be referred to DVO only if the assessee disputes the stamp duty value of the property. Thus, it is the plea of the assessee that invocation of section 56(2)(vii) is itself wrong. - AT
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