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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Income accrued in India - profit on supply of equipment - offshore supply - goods were sold from outside India, thus, the risk and title were also transferred outside India and no transaction took place in India- the custom clearance, inland transportation were done by purchaser and assessee at no stage involved in the said activities - no PE involved in the sale it only done supervision after the supply of equipments - not taxable
Income accrued in India - profit on supply of equipment - offshore supply - goods were sold from outside India, thus, the risk and title were also transferred outside India and no transaction took place in India- the custom clearance, inland transportation were done by purchaser and assessee at no stage involved in the said activities - no PE involved in the sale it only done supervision after the supply of equipments - not taxable
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