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...
Penalty proceedings u/s 271FA - late filing of the SFT statement Online by the appellant - appellant opted for the Vivad Se Vishwas Scheme and paid the due amount - Form No.4 was not submitted electronically - The Tribunal accepted the manual submission of Form No. 4 under the Vivad Se Vishwas Scheme, considering technical difficulties faced by the appellant. - The Tribunal allowed the appeal of the assessee, providing relief from the penalty imposed under section 271FA of the Income Tax Act.
Penalty proceedings u/s 271FA - late filing of the SFT statement Online by the appellant - appellant opted for the Vivad Se Vishwas Scheme and paid the due amount - Form No.4 was not submitted electronically - The Tribunal accepted the manual submission of Form No. 4 under the Vivad Se Vishwas Scheme, considering technical difficulties faced by the appellant. - The Tribunal allowed the appeal of the assessee, providing relief from the penalty imposed under section 271FA of the Income Tax Act.
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