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...
Revision u/s 264 - penalty u/s 270A imposed - waiver of penalty u/s 270AA - The very fact that the indications were made that the matter fall within (a) and (c), necessarily means that even the revisional authority was not sure whether it was a case of misrepresentation or suppression of facts or claim of expense, not substantiated by any evidence. - Order passed by the assessing authority rejecting application u/s 270AA and the order passed by the revisional authority rejecting revision petition, cannot be sustained. - HC
Revision u/s 264 - penalty u/s 270A imposed - waiver of penalty u/s 270AA - The very fact that the indications were made that the matter fall within (a) and (c), necessarily means that even the revisional authority was not sure whether it was a case of misrepresentation or suppression of facts or claim of expense, not substantiated by any evidence. - Order passed by the assessing authority rejecting application u/s 270AA and the order passed by the revisional authority rejecting revision petition, cannot be sustained. - HC
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