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...
Reopening of assessment u/s 147 - reasons to believe - notice u/s 148A(b) - the case of the petitioner is covered by information specified in Explanation 1(i) of Section 148 of the IT Act. It is not the case of the petitioner that information disclosed vide notice under Section 148A(b) of the IT Act is not covered by the information specified in Explanation 1(i) of Section 148 of the IT Act. - We respectfully disagree with the judgment of Charu Chains and Jewels Pvt. Ltd. [2023 (1) TMI 486 - DELHI HIGH COURT] - HC
Reopening of assessment u/s 147 - reasons to believe - notice u/s 148A(b) - the case of the petitioner is covered by information specified in Explanation 1(i) of Section 148 of the IT Act. It is not the case of the petitioner that information disclosed vide notice under Section 148A(b) of the IT Act is not covered by the information specified in Explanation 1(i) of Section 148 of the IT Act. - We respectfully disagree with the judgment of Charu Chains and Jewels Pvt. Ltd. [2023 (1) TMI 486 - DELHI HIGH COURT] - HC
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