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 High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search operation in 2019, leading to an assessment order in 2023. The petitioner had appealed successfully against disallowances u/s 40(a)(ia) in the original assessment u/s 143(3). A subsequent notice u/s 148 related to a search in 2022, limited to AY 2014-15 per Section 149(1) proviso. Referring to Filatex India Ltd. and Ojjus Medicare Pvt. Ltd., the Court found AY 2013-14 outside the ten-year block period u/s 153C and 153A, making the notice unsustainable.
The High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search operation in 2019, leading to an assessment order in 2023. The petitioner had appealed successfully against disallowances u/s 40(a)(ia) in the original assessment u/s 143(3). A subsequent notice u/s 148 related to a search in 2022, limited to AY 2014-15 per Section 149(1) proviso. Referring to Filatex India Ltd. and Ojjus Medicare Pvt. Ltd., the Court found AY 2013-14 outside the ten-year block period u/s 153C and 153A, making the notice unsustainable.
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