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...
Rectification u/s 254 - assessee claimed that contract were not forward contracts by virtue of proviso clauses (a)&(b) to Section 43(5) - the earlier portion of the main impugned order specifically noticed the compilation of documents produced during the proceedings, which contained specific contracts and the transactions which the Revenue alleged were speculative - remanded to consider the contentions
Rectification u/s 254 - assessee claimed that contract were not forward contracts by virtue of proviso clauses (a)&(b) to Section 43(5) - the earlier portion of the main impugned order specifically noticed the compilation of documents produced during the proceedings, which contained specific contracts and the transactions which the Revenue alleged were speculative - remanded to consider the contentions
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