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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Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
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