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...
Revision u/s 263 - Addition u/s 2(22)(e) - alleged loan & advances to concern - in assessment proceedings the Assessee had in fact placed audited statements which showed that sum received through AAIPL had been converted to shares allotted to AAIPL during AY 2014-15 - revenue has not been able to persuade this Court that the amount remained in the nature of loans and advances - no revision
Revision u/s 263 - Addition u/s 2(22)(e) - alleged loan & advances to concern - in assessment proceedings the Assessee had in fact placed audited statements which showed that sum received through AAIPL had been converted to shares allotted to AAIPL during AY 2014-15 - revenue has not been able to persuade this Court that the amount remained in the nature of loans and advances - no revision
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