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 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional Commissioner of Income Tax was not in accordance with the provisions of Section 151, which required approval from a higher authority after the lapse of four years from the relevant assessment year. Therefore, the Tribunal quashed the reassessment order on the grounds of the lack of valid approval, thereby allowing the appeal of the assessee.
Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional Commissioner of Income Tax was not in accordance with the provisions of Section 151, which required approval from a higher authority after the lapse of four years from the relevant assessment year. Therefore, the Tribunal quashed the reassessment order on the grounds of the lack of valid approval, thereby allowing the appeal of the assessee.
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