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...
Adjustments / additions u/s 143(1) - CPC made disallowed without considering the objections / reply filed by the assessee - Empty formality - Ld. NFAC ought to have considered the above additional documents and adjudicated the case in accordance with law. Since it is only a proceeding u/s. 143(1) and not a scrutiny assessment where assessee is expected to file all necessary documents along with the Return of Income. - Matter restored back to re-adjudicate the issue - AT
Adjustments / additions u/s 143(1) - CPC made disallowed without considering the objections / reply filed by the assessee - Empty formality - Ld. NFAC ought to have considered the above additional documents and adjudicated the case in accordance with law. Since it is only a proceeding u/s. 143(1) and not a scrutiny assessment where assessee is expected to file all necessary documents along with the Return of Income. - Matter restored back to re-adjudicate the issue - AT
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