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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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Rectification u/s 254(2) - receipt from other advertisers towards sale of online ad space in Inida under AdWord Program is chargeable to tax as 'Royalty - issue is highly debatable and two views are possible. It would not be appropriate to exercise powers u/s.254(2) of the Act as the order does not suffer from any mistake apparent on the face of the record.
Rectification u/s 254(2) - receipt from other advertisers towards sale of online ad space in Inida under AdWord Program is chargeable to tax as 'Royalty - issue is highly debatable and two views are possible. It would not be appropriate to exercise powers u/s.254(2) of the Act as the order does not suffer from any mistake apparent on the face of the record.
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