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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Reopening of assessment u/s 147 - reason to believe - Transaction of purchases being made by the petitioner from M/s NSE had been found to be bogus one on the basis of subsequent information, the mere disclosure of the same at the time of original assessment proceedings could not be considered to be disclosure of “true” and “full” facts and, therefore, in our opinion, the assessing officer certainly had jurisdiction to re-open the concluded assessment. - HC
Reopening of assessment u/s 147 - reason to believe - Transaction of purchases being made by the petitioner from M/s NSE had been found to be bogus one on the basis of subsequent information, the mere disclosure of the same at the time of original assessment proceedings could not be considered to be disclosure of “true” and “full” facts and, therefore, in our opinion, the assessing officer certainly had jurisdiction to re-open the concluded assessment. - HC
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