Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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The ITAT affirmed the CIT(A)'s decision and dismissed all Revenue grounds, holding the impugned final assessment order vitiated. The AO's initiation under s.153C was invalid because a single consolidated satisfaction note for multiple distinct assessees and assessment years was recorded instead of distinct, year-wise satisfactions as mandated; seized material was not analyzed qua each assessment year. Applying the principle that incriminating material must be shown to pertain to a particular year, the Tribunal found non-compliance with ss.124-127 and s.153C. Further, because the assessee (a foreign non-resident and an "eligible assessee" under s.144C(15)(b)) did not receive a draft assessment as required by s.144C(1), the final order was vitiated and set aside.
The ITAT affirmed the CIT(A)'s decision and dismissed all Revenue grounds, holding the impugned final assessment order vitiated. The AO's initiation under s.153C was invalid because a single consolidated satisfaction note for multiple distinct assessees and assessment years was recorded instead of distinct, year-wise satisfactions as mandated; seized material was not analyzed qua each assessment year. Applying the principle that incriminating material must be shown to pertain to a particular year, the Tribunal found non-compliance with ss.124-127 and s.153C. Further, because the assessee (a foreign non-resident and an "eligible assessee" under s.144C(15)(b)) did not receive a draft assessment as required by s.144C(1), the final order was vitiated and set aside.
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