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...
Revision u/s 263 - Invocation of revision proceedings for the second time - As pertinent to point out that there was no bar on limitation by the ld. PCIT to invoke section 263 for the second time considering the order to be erroneous insofar as it is prejudicial to the interest of the Revenue for the reason that the A.O. has not gone into the issue of the impugned investment which was part of the first section 263 proceeding. - AT
Revision u/s 263 - Invocation of revision proceedings for the second time - As pertinent to point out that there was no bar on limitation by the ld. PCIT to invoke section 263 for the second time considering the order to be erroneous insofar as it is prejudicial to the interest of the Revenue for the reason that the A.O. has not gone into the issue of the impugned investment which was part of the first section 263 proceeding. - AT
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