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...
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Levy of penalty u/s 271(1)(c) - Failure to offer full amount of Interest earned on income-tax refund as taxable income - The assessee did not contest this addition, acknowledging their mistake - The assessee explained that the interest component not returned in the impugned year was returned in the succeeding year. Therefore, the penalty for concealment or furnishing inaccurate particulars of income is untenable, and it is directed to be deleted. - AT
Levy of penalty u/s 271(1)(c) - Failure to offer full amount of Interest earned on income-tax refund as taxable income - The assessee did not contest this addition, acknowledging their mistake - The assessee explained that the interest component not returned in the impugned year was returned in the succeeding year. Therefore, the penalty for concealment or furnishing inaccurate particulars of income is untenable, and it is directed to be deleted. - AT
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