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 ITAT upheld the revision order u/s 263 The PCIT demonstrated that the Assessing Officer failed to examine/inquire/investigate transactions in the demat account, bank account, and receipts as per Form 26AS vis-`a-vis the Income Tax Return, despite being required to conduct adequate examinations/inquiries/investigations to arrive at a logical conclusion. The assessee did not rebut the PCIT's finding or provide evidence of the AO examining these issues. Consequently, the Tribunal ruled that the PCIT rightly exercised jurisdiction u/s 263, and the decision went against the assessee.
The ITAT upheld the revision order u/s 263 The PCIT demonstrated that the Assessing Officer failed to examine/inquire/investigate transactions in the demat account, bank account, and receipts as per Form 26AS vis-`a-vis the Income Tax Return, despite being required to conduct adequate examinations/inquiries/investigations to arrive at a logical conclusion. The assessee did not rebut the PCIT's finding or provide evidence of the AO examining these issues. Consequently, the Tribunal ruled that the PCIT rightly exercised jurisdiction u/s 263, and the decision went against the assessee.
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