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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Validity of reopening of assessment u/s 147 - reason to believe - As prima-facie the information which formed the basis of re-opening itself does not fall within the meaning of the term ‘information’ under the 1st Explanation to Section 148 of the Act and hence, the re-opening is not permissible as it clearly falls within the purview of a ‘change of opinion’ which is impermissible in law. - HC
Validity of reopening of assessment u/s 147 - reason to believe - As prima-facie the information which formed the basis of re-opening itself does not fall within the meaning of the term ‘information’ under the 1st Explanation to Section 148 of the Act and hence, the re-opening is not permissible as it clearly falls within the purview of a ‘change of opinion’ which is impermissible in law. - HC
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