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...
Validity of Reopening of assessment - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC
Validity of Reopening of assessment - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC
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