Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
Revision u/s 263 - Deemed dividend u/s 2(22)(e) - loans received from another company - beneficial ownership - voting power fall below the specified criteria - finding of error by the CIT in the assessment order for non-invocation of section 2(22)(e) of the Act on the loans received by the assessee from MAP Ltd. palpably fails on facts recorded by the Ld.PCIT himself. - AT
Revision u/s 263 - Deemed dividend u/s 2(22)(e) - loans received from another company - beneficial ownership - voting power fall below the specified criteria - finding of error by the CIT in the assessment order for non-invocation of section 2(22)(e) of the Act on the loans received by the assessee from MAP Ltd. palpably fails on facts recorded by the Ld.PCIT himself. - AT
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