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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Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for reopening the assessments did not meet the legal standards set forth in the Income Tax Act and relevant case law. The court found that there were only reasons to suspect, rather than reasons to believe, that income had escaped assessment. As a result, the court quashed the impugned notices and the order rejecting objections, ruling in favor of the petitioner.
Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for reopening the assessments did not meet the legal standards set forth in the Income Tax Act and relevant case law. The court found that there were only reasons to suspect, rather than reasons to believe, that income had escaped assessment. As a result, the court quashed the impugned notices and the order rejecting objections, ruling in favor of the petitioner.
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