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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The ITAT held that the intimation under section 143(1) issued on 30.03.2019 was invalid as it was passed before the expiry of the mandatory 30-day period provided to the assessee for submitting a response, which ended on 22.04.2019. The purported response date of 23.03.2019 was found to be incorrect and inconsistent with the record. Consequently, the Tribunal ruled that the intimation was bad in law for non-compliance with the statutory procedural requirement. As a result, the disallowance made by the AO pursuant to the impugned intimation was deleted. The appeal filed by the assessee was allowed.
The ITAT held that the intimation under section 143(1) issued on 30.03.2019 was invalid as it was passed before the expiry of the mandatory 30-day period provided to the assessee for submitting a response, which ended on 22.04.2019. The purported response date of 23.03.2019 was found to be incorrect and inconsistent with the record. Consequently, the Tribunal ruled that the intimation was bad in law for non-compliance with the statutory procedural requirement. As a result, the disallowance made by the AO pursuant to the impugned intimation was deleted. The appeal filed by the assessee was allowed.
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