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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HC partially set aside assessment order concerning disputed "Security Wages" treatment, finding procedural deficiency as this issue was not specifically mentioned in show cause notice which only referenced "Administration Expenses." Court determined petitioner was denied natural justice by not receiving opportunity for personal hearing on security wages matter. Order remanded to respondent for fresh consideration specifically regarding security wages component. While granting liberty to file appeal on remaining assessment issues, HC cautioned against piecemeal appeals. Original assessment dated 30.08.2024 remains valid on all other aspects pending potential comprehensive appeal by petitioner.
HC partially set aside assessment order concerning disputed "Security Wages" treatment, finding procedural deficiency as this issue was not specifically mentioned in show cause notice which only referenced "Administration Expenses." Court determined petitioner was denied natural justice by not receiving opportunity for personal hearing on security wages matter. Order remanded to respondent for fresh consideration specifically regarding security wages component. While granting liberty to file appeal on remaining assessment issues, HC cautioned against piecemeal appeals. Original assessment dated 30.08.2024 remains valid on all other aspects pending potential comprehensive appeal by petitioner.
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