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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Valuation of goods - Related person - it is established beyond doubt that the discounts offered are exclusive discounts only to the appellant who is 100% subsidiary of the principal company. Therefore, the appellant's contention that they are eligible for discount of upto 30% for the transfer price is not acceptable - AT
Valuation of goods - Related person - it is established beyond doubt that the discounts offered are exclusive discounts only to the appellant who is 100% subsidiary of the principal company. Therefore, the appellant's contention that they are eligible for discount of upto 30% for the transfer price is not acceptable - AT
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