Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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Validity of reopening of assessment - reasons to believe - The Appellate Tribunal scrutinized the reasons recorded for the reopening of the assessment and found several discrepancies. Firstly, it was noted that the AO incorrectly stated that the assessee claimed expenses on the amortization of goodwill, which was contradicted by the assessee's computation of total income and balance sheet. Additionally, the Tribunal observed that the AO overlooked the previous assessment completed under section 143(3) r.w.s. 153C of the Act. The Tribunal concluded that the reopening of the assessment was invalid and without jurisdiction. Consequently, the Tribunal allowed the appeal of the assessee on legal grounds.
Validity of reopening of assessment - reasons to believe - The Appellate Tribunal scrutinized the reasons recorded for the reopening of the assessment and found several discrepancies. Firstly, it was noted that the AO incorrectly stated that the assessee claimed expenses on the amortization of goodwill, which was contradicted by the assessee's computation of total income and balance sheet. Additionally, the Tribunal observed that the AO overlooked the previous assessment completed under section 143(3) r.w.s. 153C of the Act. The Tribunal concluded that the reopening of the assessment was invalid and without jurisdiction. Consequently, the Tribunal allowed the appeal of the assessee on legal grounds.
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