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...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Valuation of consideration for a limited patent-use licence turned on materially divergent expert reports applying an internationally accepted cost approach and a substantially higher departmental valuation. Neither valuation position was accepted in full. A lump-sum estimate was adopted in the interest of justice, expressly without precedential effect, fixing the amount attributable to the limited patent-use right at USD 900,000. Consequential computation was directed in accordance with law, and the appeal was partly allowed to that extent.
Valuation of consideration for a limited patent-use licence turned on materially divergent expert reports applying an internationally accepted cost approach and a substantially higher departmental valuation. Neither valuation position was accepted in full. A lump-sum estimate was adopted in the interest of justice, expressly without precedential effect, fixing the amount attributable to the limited patent-use right at USD 900,000. Consequential computation was directed in accordance with law, and the appeal was partly allowed to that extent.
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