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...
If the assessment order itself has been quashed then challenging the deletion of additions on merits is purely academic, because the assessment itself is quashed and held to be invalid against which there is no appeal. If the additional grounds is with regard to principle of natural justice on which ld. CIT (A) has given his remarks that also cannot be treated as additional ground. Consequently, all the grounds raised by the department is dismissed. - AT
If the assessment order itself has been quashed then challenging the deletion of additions on merits is purely academic, because the assessment itself is quashed and held to be invalid against which there is no appeal. If the additional grounds is with regard to principle of natural justice on which ld. CIT (A) has given his remarks that also cannot be treated as additional ground. Consequently, all the grounds raised by the department is dismissed. - AT
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