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...
Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay
Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay
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