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 Appellate Tribunal considered the validity of physical/manual filing of appeal u/s the Income Tax Rules. Assessee argued inability to e-file due to lack of assistance and incomplete requirements. Tribunal noted physical filing before due date and CBDT's extension of e-filing time limit due to difficulties. Held that physical filing was valid, directing CIT(A) to admit and decide the appeal on merits, providing ample hearing opportunity to the assessee. Remanded the matter for fresh consideration.
The Appellate Tribunal considered the validity of physical/manual filing of appeal u/s the Income Tax Rules. Assessee argued inability to e-file due to lack of assistance and incomplete requirements. Tribunal noted physical filing before due date and CBDT's extension of e-filing time limit due to difficulties. Held that physical filing was valid, directing CIT(A) to admit and decide the appeal on merits, providing ample hearing opportunity to the assessee. Remanded the matter for fresh consideration.
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