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...
Assessment u/s 153A - validity of granting the approval u/s 153D - The action of the JCIT granting approval in this case was a mere mechanical exercise, accepting the draft order as it is, without any independent application of mind on his part. His action of granting the approval was thus, a mere mechanical exercise accepting the draft order as it is without any independent application of mind on his part. - Assessment orders passed u/s 153A r.w.s. 143 (3) stand cancelled. - AT
Assessment u/s 153A - validity of granting the approval u/s 153D - The action of the JCIT granting approval in this case was a mere mechanical exercise, accepting the draft order as it is, without any independent application of mind on his part. His action of granting the approval was thus, a mere mechanical exercise accepting the draft order as it is without any independent application of mind on his part. - Assessment orders passed u/s 153A r.w.s. 143 (3) stand cancelled. - AT
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