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...
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
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