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...
Composite EPC/turnkey public utility construction contracts for Government agencies were held not to be Consulting Engineer's service because the agreements showed complete construction, procurement, labour, commissioning, quality and maintenance obligations, with the fee representing only the contractor's profit margin. The Revenue could not vivisect the contract and tax only the fee component under that head, so the demand failed on classification. The extended period was also inapplicable because the projects were treated as exempt public utility works, the assessee acted under bona fide belief, and there was no specific evidence of wilful suppression or intent to evade.
Composite EPC/turnkey public utility construction contracts for Government agencies were held not to be Consulting Engineer's service because the agreements showed complete construction, procurement, labour, commissioning, quality and maintenance obligations, with the fee representing only the contractor's profit margin. The Revenue could not vivisect the contract and tax only the fee component under that head, so the demand failed on classification. The extended period was also inapplicable because the projects were treated as exempt public utility works, the assessee acted under bona fide belief, and there was no specific evidence of wilful suppression or intent to evade.
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