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...
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Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
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