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 - includibility - advertisement expenses - the 50% is borne by the dealers/distributors which is the expenses of the dealers/distributors and the appellant is nothing to do with that portion of the 50% - Amount of such advertisement is not flowing to the appellant as an additional consideration. - demand set aside - AT
Valuation - includibility - advertisement expenses - the 50% is borne by the dealers/distributors which is the expenses of the dealers/distributors and the appellant is nothing to do with that portion of the 50% - Amount of such advertisement is not flowing to the appellant as an additional consideration. - demand set aside - AT
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