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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ITAT adjudicated a dispute regarding tax assessment in a precious metal business. The tribunal found the Assessing Officer (AO) improperly rejected audited books under Section 145(3) without conducting a mandatory special audit under Section 142(2A). The ad-hoc income determination was deemed capricious and irrational, lacking cogent material and expert assessment. Given the complex business nature involving high-value transactions and inventory volatility, the tribunal disapproved the arbitrary income estimation. The matter was remanded to the AO for fresh income determination in strict compliance with legal provisions, with the appeal allowed for statistical purposes.
ITAT adjudicated a dispute regarding tax assessment in a precious metal business. The tribunal found the Assessing Officer (AO) improperly rejected audited books under Section 145(3) without conducting a mandatory special audit under Section 142(2A). The ad-hoc income determination was deemed capricious and irrational, lacking cogent material and expert assessment. Given the complex business nature involving high-value transactions and inventory volatility, the tribunal disapproved the arbitrary income estimation. The matter was remanded to the AO for fresh income determination in strict compliance with legal provisions, with the appeal allowed for statistical purposes.
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