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 finds the impugned CIT(A) order to be cryptic and nonspeaking, lacking independent findings and adequate application of mind to the assessee's submissions and bank records; it also records the AO's failure, without satisfactory explanation, to file the remand report despite two opportunities. Noting absence of evidence for the revenue's asserted reasons for non-compliance, and that the AO proceeded to assess under section 144 without full compliance by the assessee, ITAT sets aside the CIT(A) order and remands the matter to the AO for fresh adjudication. AO is directed to examine the additional evidence produced by the assessee, obtain any necessary bank records, and decide the matter on merits.
ITAT finds the impugned CIT(A) order to be cryptic and nonspeaking, lacking independent findings and adequate application of mind to the assessee's submissions and bank records; it also records the AO's failure, without satisfactory explanation, to file the remand report despite two opportunities. Noting absence of evidence for the revenue's asserted reasons for non-compliance, and that the AO proceeded to assess under section 144 without full compliance by the assessee, ITAT sets aside the CIT(A) order and remands the matter to the AO for fresh adjudication. AO is directed to examine the additional evidence produced by the assessee, obtain any necessary bank records, and decide the matter on merits.
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