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...
Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
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