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...
Revision u/s 263 - sale of preferential shares - PCIT noted a discrepancy between the value of shares sold as per the audited balance sheet and the value declared in the income computation sheet. - The tribunal noted that, the assessee had gone on to explain even this difference between sale consideration and cost of acquisition to have been duly considered and accounted for in the return of income. - Accordingly the ITAT held that, we completely agree with assessee that there was no error in the assessment order on account of non-inquiry/inadequate inquiry relating to the issue of preferential shares sold during the year.
Revision u/s 263 - sale of preferential shares - PCIT noted a discrepancy between the value of shares sold as per the audited balance sheet and the value declared in the income computation sheet. - The tribunal noted that, the assessee had gone on to explain even this difference between sale consideration and cost of acquisition to have been duly considered and accounted for in the return of income. - Accordingly the ITAT held that, we completely agree with assessee that there was no error in the assessment order on account of non-inquiry/inadequate inquiry relating to the issue of preferential shares sold during the year.
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