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 CIT(A) partly allowed and restricted the addition on account of commission expenses at 0.25% as compared to 2% adopted by the Assessing Officer. The coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine profit/loss in illiquid options and consequently also deleted the notional addition of commission u/s 69C. Following the same, the addition on account of commission expenses u/s 69C is deleted. Regarding the addition on account of non-genuine purchases, the coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine purchases. In the absence of contradictory material on facts and law, the addition on account of non-genuine purchases is also deleted, respectfully following the Tribunal's decision in the cited case.
The CIT(A) partly allowed and restricted the addition on account of commission expenses at 0.25% as compared to 2% adopted by the Assessing Officer. The coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine profit/loss in illiquid options and consequently also deleted the notional addition of commission u/s 69C. Following the same, the addition on account of commission expenses u/s 69C is deleted. Regarding the addition on account of non-genuine purchases, the coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine purchases. In the absence of contradictory material on facts and law, the addition on account of non-genuine purchases is also deleted, respectfully following the Tribunal's decision in the cited case.
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