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...
Eligibility to claim credit for the tax deducted in Japan - the treatment sought to be given by Revenue in the case of the assessee yields absurd result - Accordingly assessee should be treated to have paid tax in India without giving effect to the provision of section 10A for the reason also of Article 24 of Double Taxation Avoidance Convention between India and Japan. - AT
Eligibility to claim credit for the tax deducted in Japan - the treatment sought to be given by Revenue in the case of the assessee yields absurd result - Accordingly assessee should be treated to have paid tax in India without giving effect to the provision of section 10A for the reason also of Article 24 of Double Taxation Avoidance Convention between India and Japan. - AT
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