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 reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
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