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 held that for reassessment proceedings under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment, not the search date. The ten-year block is calculated from the end of AY 2024-25, when the notice was issued on 30.03.2024. Consistent with prior judicial precedents, the court found the impugned notice barred by limitation and allowed the petition, setting aside the notice as time-barred.
HC held that for reassessment proceedings under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment, not the search date. The ten-year block is calculated from the end of AY 2024-25, when the notice was issued on 30.03.2024. Consistent with prior judicial precedents, the court found the impugned notice barred by limitation and allowed the petition, setting aside the notice as time-barred.
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