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...
Validity of Revision u/s 263 by CIT - The tribunal, after examining the factual aspects and noting that full details of the stock were furnished, found that the revenue failed to demonstrate any shortage or undervaluation in the stock. It also observed that the CIT did not specifically address whether these details were available to the assessing officer during the original proceedings. - Ultimately, the High court was satisfied with the tribunal's findings and reasoning, dismissed the revenue appeal.
Validity of Revision u/s 263 by CIT - The tribunal, after examining the factual aspects and noting that full details of the stock were furnished, found that the revenue failed to demonstrate any shortage or undervaluation in the stock. It also observed that the CIT did not specifically address whether these details were available to the assessing officer during the original proceedings. - Ultimately, the High court was satisfied with the tribunal's findings and reasoning, dismissed the revenue appeal.
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