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...
Classification of services - Franchise services or not - slump sale of business of marketing - None of the ingredients of franchisee service or the Board Circular are present in the BPA between the Appellant and M/s Aventis - the Appellants do not qualify as Franchisor as the trademarks have been permanently assigned to M/s Aventis and they have become absolute owner with no control of the Appellant - no service tax
Classification of services - Franchise services or not - slump sale of business of marketing - None of the ingredients of franchisee service or the Board Circular are present in the BPA between the Appellant and M/s Aventis - the Appellants do not qualify as Franchisor as the trademarks have been permanently assigned to M/s Aventis and they have become absolute owner with no control of the Appellant - no service tax
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