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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Revision u/s 263 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
Revision u/s 263 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
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