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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Penalty u/s. 271(1)(c) for under reporting income - defective notice - The Tribunal agrees with the appellant's argument, emphasizing that the AO did not apply his mind properly while initiating the penalty proceedings - The Tribunal rules in favor of the appellant, stating that the penalty proceedings were not validly initiated due to the lack of clarity in the penalty charge. - As a result, the penalty is deleted for all assessment years under consideration.
Penalty u/s. 271(1)(c) for under reporting income - defective notice - The Tribunal agrees with the appellant's argument, emphasizing that the AO did not apply his mind properly while initiating the penalty proceedings - The Tribunal rules in favor of the appellant, stating that the penalty proceedings were not validly initiated due to the lack of clarity in the penalty charge. - As a result, the penalty is deleted for all assessment years under consideration.
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