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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Disallowance u/s 40(a)(ia) of Wharfage charges - Wharfage charges paid by assessee are charges which facilitate the loading / unloading of goods at waterfront - no use of land but even if it was held that there is any use of land, then the same was incidental - cannot be equated to be a charge for ‘rent’ for use of water - No TDS u/s 194I - allowed as deduction u/s 37(1)
Disallowance u/s 40(a)(ia) of Wharfage charges - Wharfage charges paid by assessee are charges which facilitate the loading / unloading of goods at waterfront - no use of land but even if it was held that there is any use of land, then the same was incidental - cannot be equated to be a charge for ‘rent’ for use of water - No TDS u/s 194I - allowed as deduction u/s 37(1)
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