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...
Assessee fails whether the enhancement in its income is considered as on account of a TP adjustment or for denial of deduction u/s. 10A, i.e., from the standpoint of both Explanation 1 or 7 to s. 271(1)(c) – the levy of penalty upheld - AT
Assessee fails whether the enhancement in its income is considered as on account of a TP adjustment or for denial of deduction u/s. 10A, i.e., from the standpoint of both Explanation 1 or 7 to s. 271(1)(c) – the levy of penalty upheld - AT
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