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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The Delhi High Court examined the validity of reassessment proceedings u/s 147 after a four-year lapse. The court emphasized the requirement of "reasons to believe" for reopening assessments. It noted that the AO lacked specific grounds for reassessment, resembling past cases. The CIT(A) upheld reassessment based on a revenue audit report, but failed to establish a direct link between reasons and belief u/s 147. The court found the initiation of reassessment after four years without fresh material as legally unsound, rejecting the Revenue's case. The decision favored the assessee, emphasizing the need for concrete grounds for reassessment within the statutory period.
The Delhi High Court examined the validity of reassessment proceedings u/s 147 after a four-year lapse. The court emphasized the requirement of "reasons to believe" for reopening assessments. It noted that the AO lacked specific grounds for reassessment, resembling past cases. The CIT(A) upheld reassessment based on a revenue audit report, but failed to establish a direct link between reasons and belief u/s 147. The court found the initiation of reassessment after four years without fresh material as legally unsound, rejecting the Revenue's case. The decision favored the assessee, emphasizing the need for concrete grounds for reassessment within the statutory period.
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