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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Onus on petitioner partnership firm to show unexplained investment and expenditure belonged to partners. No records showing partners had substantial income to lend Rs. 1.01 crore. Firm had rental income used for maintenance. No infirmity in impugned order rejecting petition u/s 264. Objection on non-issuance of notice u/s 143(2) within 6 months not countenanced as not raised earlier. Section 292BB deems notice valid if assessee participated in proceedings, except if no notice issued. Explanatory Note to Finance Act, 2008 clarifies legal fiction inapplicable if objection not raised before assessment completion. Petition dismissed.
Onus on petitioner partnership firm to show unexplained investment and expenditure belonged to partners. No records showing partners had substantial income to lend Rs. 1.01 crore. Firm had rental income used for maintenance. No infirmity in impugned order rejecting petition u/s 264. Objection on non-issuance of notice u/s 143(2) within 6 months not countenanced as not raised earlier. Section 292BB deems notice valid if assessee participated in proceedings, except if no notice issued. Explanatory Note to Finance Act, 2008 clarifies legal fiction inapplicable if objection not raised before assessment completion. Petition dismissed.
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