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...
Liability for the Special Auditor's fee was addressed where the appointment preceded the amendment effective 1 June 2007, but the audit was conducted under the Assessing Officer's order. The HC considered the spirit of the amendment and the assessee's non-appearance despite service, and directed the Union of India to bear the audit cost. The writ petition was disposed of because the special audit had already been completed.
Liability for the Special Auditor's fee was addressed where the appointment preceded the amendment effective 1 June 2007, but the audit was conducted under the Assessing Officer's order. The HC considered the spirit of the amendment and the assessee's non-appearance despite service, and directed the Union of India to bear the audit cost. The writ petition was disposed of because the special audit had already been completed.
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