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...
The ITAT dealt with a case involving a Revision u/s 263. The PCIT alleged that the AO did not inquire into cash deposits during demonetization or non-disclosure of income from scrap sales. However, the ITAT found that the AO had conducted proper inquiries based on assessment records, notices issued u/s 142(1), and replies from the assessee. The PCIT's allegations were deemed unfounded as the assessment order was not erroneous or prejudicial to revenue. The ITAT emphasized that invoking section 263 requires meeting specific conditions and that the revisionary authority cannot act arbitrarily. The decision favored the assessee due to lack of evidence supporting the PCIT's allegations.
The ITAT dealt with a case involving a Revision u/s 263. The PCIT alleged that the AO did not inquire into cash deposits during demonetization or non-disclosure of income from scrap sales. However, the ITAT found that the AO had conducted proper inquiries based on assessment records, notices issued u/s 142(1), and replies from the assessee. The PCIT's allegations were deemed unfounded as the assessment order was not erroneous or prejudicial to revenue. The ITAT emphasized that invoking section 263 requires meeting specific conditions and that the revisionary authority cannot act arbitrarily. The decision favored the assessee due to lack of evidence supporting the PCIT's allegations.
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