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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Disallowance u/s 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
Disallowance u/s 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
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