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...
Penalty u/s. 271B - assessee had not filed audit report - Only a qualified CA is permitted to Audit books of account. In the affidavit it is claimed by the Accountant of the firm, that he had not given data to CA. Thus, in the affidavit he is not referring to books. However, for Audit, books of account are required. Therefore, the claims made in the affidavit are contradictory and hence not reliable. - Levy of penalty confirmed - AT
Penalty u/s. 271B - assessee had not filed audit report - Only a qualified CA is permitted to Audit books of account. In the affidavit it is claimed by the Accountant of the firm, that he had not given data to CA. Thus, in the affidavit he is not referring to books. However, for Audit, books of account are required. Therefore, the claims made in the affidavit are contradictory and hence not reliable. - Levy of penalty confirmed - AT
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