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...
Maintainability of appeal in writ Court - Validity of re-assessment order passed u/s 147 - The High court, after hearing both parties and reviewing the submissions and relevant case law, concluded that the appellant did not challenge the initial stages of the re-assessment process and, therefore, could not question the correctness of the order passed under Section 148A(d) at this stage. The court also noted that the appellant participated in the re-assessment proceedings and had the opportunity to present their case. - The court dismissed the appeal.
Maintainability of appeal in writ Court - Validity of re-assessment order passed u/s 147 - The High court, after hearing both parties and reviewing the submissions and relevant case law, concluded that the appellant did not challenge the initial stages of the re-assessment process and, therefore, could not question the correctness of the order passed under Section 148A(d) at this stage. The court also noted that the appellant participated in the re-assessment proceedings and had the opportunity to present their case. - The court dismissed the appeal.
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