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...
Penalties for alleged violations of cash loan and repayment restrictions were treated as consequential to the quantum assessments in which the underlying findings were recorded. Once the co-ordinate Bench had quashed the assessee's quantum assessments, the foundation for the penalty orders disappeared, and the penalties had no independent existence to survive. The Tribunal therefore deleted all the penalties for the years in appeal and rejected the request to keep the matters pending, while leaving the Department free to seek revival if it later succeeded in the quantum proceedings.
Penalties for alleged violations of cash loan and repayment restrictions were treated as consequential to the quantum assessments in which the underlying findings were recorded. Once the co-ordinate Bench had quashed the assessee's quantum assessments, the foundation for the penalty orders disappeared, and the penalties had no independent existence to survive. The Tribunal therefore deleted all the penalties for the years in appeal and rejected the request to keep the matters pending, while leaving the Department free to seek revival if it later succeeded in the quantum proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
