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 held that the Assessing Officer (AO) lacked valid jurisdictional grounds for reopening the assessment. Despite having territorial jurisdiction, the AO failed to establish a substantive reason to believe income had escaped assessment. The notice was deemed invalid as it was based solely on information from an insight portal without concrete evidence connecting the alleged accommodation entries to the petitioner's audited accounts. The court found the reopening notice constituted a fishing inquiry without demonstrating a prima facie case of income escaping assessment, thereby rendering the reopening notice legally untenable and unsustainable.
HC held that the Assessing Officer (AO) lacked valid jurisdictional grounds for reopening the assessment. Despite having territorial jurisdiction, the AO failed to establish a substantive reason to believe income had escaped assessment. The notice was deemed invalid as it was based solely on information from an insight portal without concrete evidence connecting the alleged accommodation entries to the petitioner's audited accounts. The court found the reopening notice constituted a fishing inquiry without demonstrating a prima facie case of income escaping assessment, thereby rendering the reopening notice legally untenable and unsustainable.
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