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...
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Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT
Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT
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