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...
Reopening of assessment u/s 147 - notice issued u/s 148A(b) - fictitious short-term capital loss - wrongdoing by the mutual fund - The High court noted discrepancies in the department's actions, including lack of clear information provided to the petitioner and reliance on incomplete data. - It observed that the petitioner, being a minor investor, was not a key player in the alleged fraudulent activities of the mutual fund. - The court emphasized the importance of a rational connection between reasons for reopening assessment and actual evidence, which was lacking in this case. - Decision: The court quashed the show cause notice, order for reopening assessment, and related notices issued by the department.
Reopening of assessment u/s 147 - notice issued u/s 148A(b) - fictitious short-term capital loss - wrongdoing by the mutual fund - The High court noted discrepancies in the department's actions, including lack of clear information provided to the petitioner and reliance on incomplete data. - It observed that the petitioner, being a minor investor, was not a key player in the alleged fraudulent activities of the mutual fund. - The court emphasized the importance of a rational connection between reasons for reopening assessment and actual evidence, which was lacking in this case. - Decision: The court quashed the show cause notice, order for reopening assessment, and related notices issued by the department.
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