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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Deemed dividend u/s 2(22)(e) - assessee claimed the amount received as guarantee fee for advance received from Ginza - the real intent of Ginza in advancing the sums it did to the assessee was to share its profit by way of deemed dividend - Decided in favor of revenue - HC
Deemed dividend u/s 2(22)(e) - assessee claimed the amount received as guarantee fee for advance received from Ginza - the real intent of Ginza in advancing the sums it did to the assessee was to share its profit by way of deemed dividend - Decided in favor of revenue - HC
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