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...
The eighteen-month period for an Interim Board to dispose of a pending settlement application runs from its first allotment to, and action by, an Interim Board. An administrative transfer to another Interim Board does not restart or extend that limitation, because repeated transfers would undermine the statutory time-bound settlement framework. Exercise of the power to call for a report indicates that the application had already been allotted to and was within the first Interim Board's jurisdiction. The limitation period is mandatory; settlement and consequential rectification orders made after its expiry are time-barred and void. Questions concerning abatement and its consequences remain open.
The eighteen-month period for an Interim Board to dispose of a pending settlement application runs from its first allotment to, and action by, an Interim Board. An administrative transfer to another Interim Board does not restart or extend that limitation, because repeated transfers would undermine the statutory time-bound settlement framework. Exercise of the power to call for a report indicates that the application had already been allotted to and was within the first Interim Board's jurisdiction. The limitation period is mandatory; settlement and consequential rectification orders made after its expiry are time-barred and void. Questions concerning abatement and its consequences remain open.
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