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...
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Additions u/sec 68 in respect of sale of shares and u/sec 69 in respect of estimated commission expenditure - The Tribunal, relying upon the judicial precedents, found that the appellant had substantiated the genuineness of the purchase and sale of shares through banking channels and documentation. The lack of independent inquiry or substantive evidence from the AO to refute the appellant's claims led to the decision to delete the additions made under sections 68 and 69C, thereby allowing the appeal in favor of the appellant.
Additions u/sec 68 in respect of sale of shares and u/sec 69 in respect of estimated commission expenditure - The Tribunal, relying upon the judicial precedents, found that the appellant had substantiated the genuineness of the purchase and sale of shares through banking channels and documentation. The lack of independent inquiry or substantive evidence from the AO to refute the appellant's claims led to the decision to delete the additions made under sections 68 and 69C, thereby allowing the appeal in favor of the appellant.
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