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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Estimation of income - bogus purchases - The ITAT found the CIT(A)'s decision to restrict the addition to a percentage of disputed purchases as a reasonable estimation. It was noted that without knowing the parties to whom the diamonds were sold, the onus of proving the genuineness of transactions was not fully discharged by the assessee. The ITAT upheld the CIT(A)'s approach as justified and dismissed the Revenue's appeal and the assessee's cross-objection.
Estimation of income - bogus purchases - The ITAT found the CIT(A)'s decision to restrict the addition to a percentage of disputed purchases as a reasonable estimation. It was noted that without knowing the parties to whom the diamonds were sold, the onus of proving the genuineness of transactions was not fully discharged by the assessee. The ITAT upheld the CIT(A)'s approach as justified and dismissed the Revenue's appeal and the assessee's cross-objection.
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