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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Penalty u/s 271D - period of limitation - CIT(A) took the date on which the one year period from the end of the financial year in which the notice was issued as 31/03/2022. - We are unable to understand where from this date has come. Expiry of one year is not relatable to this date either from the date of the assessment order for the assessment year 2017-18 or from the date of issuance of notice u/s 271D of the Act, initiating the proceedings. - AT
Penalty u/s 271D - period of limitation - CIT(A) took the date on which the one year period from the end of the financial year in which the notice was issued as 31/03/2022. - We are unable to understand where from this date has come. Expiry of one year is not relatable to this date either from the date of the assessment order for the assessment year 2017-18 or from the date of issuance of notice u/s 271D of the Act, initiating the proceedings. - AT
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