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...
ITAT held that the revisionary proceedings u/s 263 were valid and the assessee cannot challenge the order since it had attained finality. In the substantive matter concerning unexplained cash credit u/s 68 for share capital and share premium from 18 private limited applicants, the tribunal found that the assessee successfully established the identity, genuineness, and creditworthiness of share applicants through their tax assessments, financial statements, and ROC scrutiny. Consequently, the tribunal deleted the addition u/s 68, set aside the CIT(A)'s order, and allowed the assessee's grounds 1-5, concluding no addition was warranted based on the comprehensive documentation and verification of investment sources.
ITAT held that the revisionary proceedings u/s 263 were valid and the assessee cannot challenge the order since it had attained finality. In the substantive matter concerning unexplained cash credit u/s 68 for share capital and share premium from 18 private limited applicants, the tribunal found that the assessee successfully established the identity, genuineness, and creditworthiness of share applicants through their tax assessments, financial statements, and ROC scrutiny. Consequently, the tribunal deleted the addition u/s 68, set aside the CIT(A)'s order, and allowed the assessee's grounds 1-5, concluding no addition was warranted based on the comprehensive documentation and verification of investment sources.
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