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...
HC dismissed petition for complete stay of demand. Petitioner directed to pay 20% of Rs. 5.86 crore demand in 6 installments. Additions made by AO on account of non-genuine purchases based on search, statements and investigation. Petitioner failed to rebut findings or prove purchases were genuine. No prima facie case made out for full stay or financial incapacity shown to pay 20% demand.
HC dismissed petition for complete stay of demand. Petitioner directed to pay 20% of Rs. 5.86 crore demand in 6 installments. Additions made by AO on account of non-genuine purchases based on search, statements and investigation. Petitioner failed to rebut findings or prove purchases were genuine. No prima facie case made out for full stay or financial incapacity shown to pay 20% demand.
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