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...
Accrual of income in India - TP Adjustment - when the amount remunerated by the assessee is found to be satisfying the ‘arms length’ principle, therefore, no further profits could be attributed to the assessee in India even if it was to be held that the latter had a PE in India
Accrual of income in India - TP Adjustment - when the amount remunerated by the assessee is found to be satisfying the ‘arms length’ principle, therefore, no further profits could be attributed to the assessee in India even if it was to be held that the latter had a PE in India
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