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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Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.
Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.
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