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 - reasons for re-opening within or beyond 4 years - reasons to believe - The court specifically pointed out that the information used from the DRI and the Shah Commission reports was not adequately scrutinized independently by the assessing officers to form a reasonable belief of tax evasion. The court noted that the decision of the Supreme Court, which found mining leases post-2007 to be illegal, could not retroactively make previous business activities illegal for tax purposes. The court emphasized that such interpretations were not known or could not have been known by the taxpayers at the time of filing their returns.
Reopening of assessment - reasons for re-opening within or beyond 4 years - reasons to believe - The court specifically pointed out that the information used from the DRI and the Shah Commission reports was not adequately scrutinized independently by the assessing officers to form a reasonable belief of tax evasion. The court noted that the decision of the Supreme Court, which found mining leases post-2007 to be illegal, could not retroactively make previous business activities illegal for tax purposes. The court emphasized that such interpretations were not known or could not have been known by the taxpayers at the time of filing their returns.
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