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 of demand - recovery notice during the pendency of the stay applications - Instruction No.1914 dated 02.12.1993 of the Board would make it clear that the stay petition filed with the AO must be disposed of within two weeks of the filing of petition by the taxpayer - recovery notice is obviously contrary to the Instructions and the Office Memorandum issued by the Board - calls for interference by this Court
Stay of demand - recovery notice during the pendency of the stay applications - Instruction No.1914 dated 02.12.1993 of the Board would make it clear that the stay petition filed with the AO must be disposed of within two weeks of the filing of petition by the taxpayer - recovery notice is obviously contrary to the Instructions and the Office Memorandum issued by the Board - calls for interference by this Court
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