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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Page of 4811
Press 'Enter' after typing page number.
661 to 680 of 96208 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
