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...
Protective additions for alleged secret commission receipts cannot survive after deletion of corresponding substantive additions in the hands of the alleged real beneficiary. The Tribunal's reasoning, as reported, also notes that the Commissioner (Appeals) found no substantive evidence supporting the alleged receipts, and that the taxpayer's position for relevant assessment years was supported by the cited High Court decision. Consequently, the protective additions were unsustainable and the Revenue's appeals were dismissed.
Protective additions for alleged secret commission receipts cannot survive after deletion of corresponding substantive additions in the hands of the alleged real beneficiary. The Tribunal's reasoning, as reported, also notes that the Commissioner (Appeals) found no substantive evidence supporting the alleged receipts, and that the taxpayer's position for relevant assessment years was supported by the cited High Court decision. Consequently, the protective additions were unsustainable and the Revenue's appeals were dismissed.
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