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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Section 263 revision - derivative transactions losses - inadequate inquiry by Assessing Officer (AO). Commissioner of Income Tax (CIT) set aside AO's order for re-examination instead of giving conclusive finding on sustainability under law. Distinction between lack of inquiry and inadequate inquiry - if any inquiry conducted, even inadequate, CIT cannot revise merely due to different opinion. Only lack of inquiry permits revision u/s 263. AO conducted inquiry, was satisfied with evidence provided, not required to give elaborate finding. CIT cannot remand for fresh adjudication merely due to uncertainty about assessee's claim correctness. When AO's order not erroneous for want of inquiry, CIT must give conclusive finding on order's sustainability under law. Assessee's appeal allowed.
Section 263 revision - derivative transactions losses - inadequate inquiry by Assessing Officer (AO). Commissioner of Income Tax (CIT) set aside AO's order for re-examination instead of giving conclusive finding on sustainability under law. Distinction between lack of inquiry and inadequate inquiry - if any inquiry conducted, even inadequate, CIT cannot revise merely due to different opinion. Only lack of inquiry permits revision u/s 263. AO conducted inquiry, was satisfied with evidence provided, not required to give elaborate finding. CIT cannot remand for fresh adjudication merely due to uncertainty about assessee's claim correctness. When AO's order not erroneous for want of inquiry, CIT must give conclusive finding on order's sustainability under law. Assessee's appeal allowed.
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