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...
TDS u/s 195 - grossing up - the obligation to pay the tax is on the recipient and since the assessee in terms of the agreement agreed to pay the taxes, the same has to be necessarily added to the income of the recipient and therefore, the principle of grossing up has to be applied.
TDS u/s 195 - grossing up - the obligation to pay the tax is on the recipient and since the assessee in terms of the agreement agreed to pay the taxes, the same has to be necessarily added to the income of the recipient and therefore, the principle of grossing up has to be applied.
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