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...
CIT(A) directed to first adjudicate assessee's appeal against quantum assessment, determine business turnover, and whether assessee falls within Section 44AB for audit obligation before adjudicating penalty u/s 271B for failure to furnish audit report. ITAT set aside CIT(A)'s order, restoring matter to CIT(A) for fresh adjudication in interest of justice and fairness. Assessee's appeal allowed for statistical purposes.
CIT(A) directed to first adjudicate assessee's appeal against quantum assessment, determine business turnover, and whether assessee falls within Section 44AB for audit obligation before adjudicating penalty u/s 271B for failure to furnish audit report. ITAT set aside CIT(A)'s order, restoring matter to CIT(A) for fresh adjudication in interest of justice and fairness. Assessee's appeal allowed for statistical purposes.
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