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 Tribunal held that the objection of the assessee regarding low tax effect was not sustainable. The addition made u/s 68 for bogus LTCG and unexplained cash credits involved penny stocks. The Tribunal cannot determine if a share is a penny stock, which is decided by BSE or investigation agencies. The transaction involved shares identified as penny stocks by the Investigation Directorate. The Tribunal found no merit in the objections raised by the assessee and dismissed the request to recall the order. The power u/s 254(2) cannot be used to review the order on its merits. The assessee's application is dismissed, citing judicial discipline and referring to a decision by the Supreme Court.
The Tribunal held that the objection of the assessee regarding low tax effect was not sustainable. The addition made u/s 68 for bogus LTCG and unexplained cash credits involved penny stocks. The Tribunal cannot determine if a share is a penny stock, which is decided by BSE or investigation agencies. The transaction involved shares identified as penny stocks by the Investigation Directorate. The Tribunal found no merit in the objections raised by the assessee and dismissed the request to recall the order. The power u/s 254(2) cannot be used to review the order on its merits. The assessee's application is dismissed, citing judicial discipline and referring to a decision by the Supreme Court.
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