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 HC allowed the writ petition and held that, pursuant to the Principal Bench ruling, the tax authorities are entitled to exclude the period 15.03.2020 to 28.02.2022 when computing limitation under the relevant provisions, thereby entitling the petitioner to relief. Consequently, the impugned assessment order dated 16.08.2024 issued by the first respondent for the assessment year 2019-2020 is quashed. The matter is remitted to the first respondent for fresh adjudication on merits and in accordance with law, taking into account the exclusion of the specified period; no order as to costs.
The HC allowed the writ petition and held that, pursuant to the Principal Bench ruling, the tax authorities are entitled to exclude the period 15.03.2020 to 28.02.2022 when computing limitation under the relevant provisions, thereby entitling the petitioner to relief. Consequently, the impugned assessment order dated 16.08.2024 issued by the first respondent for the assessment year 2019-2020 is quashed. The matter is remitted to the first respondent for fresh adjudication on merits and in accordance with law, taking into account the exclusion of the specified period; no order as to costs.
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