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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Rectification u/s 154 - The Assessee argued that the assessments u/s 143(1) and 143(3) merged, precluding further additions u/s 154, while the Revenue contended that they were distinct assessments. The Tribunal found that there was no merger between the assessments and upheld the validity of the rectification u/s 154. It concluded that the additions made under Section 143(1) were not revisited during the assessment u/s 143(3), necessitating rectification to correct the apparent error. The Tribunal differentiated the present case from previous precedents and dismissed the Assessee's appeal.
Rectification u/s 154 - The Assessee argued that the assessments u/s 143(1) and 143(3) merged, precluding further additions u/s 154, while the Revenue contended that they were distinct assessments. The Tribunal found that there was no merger between the assessments and upheld the validity of the rectification u/s 154. It concluded that the additions made under Section 143(1) were not revisited during the assessment u/s 143(3), necessitating rectification to correct the apparent error. The Tribunal differentiated the present case from previous precedents and dismissed the Assessee's appeal.
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