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...
TP adjustments in relation to support services in relation to External Commercial Borrowings (ECBs). - The said receipt of fee / commission income has been accepted to be at arm’s length. Hence, there is no question of further fee that is required for the assessee in respect of continuing ECBs. - No additions.
TP adjustments in relation to support services in relation to External Commercial Borrowings (ECBs). - The said receipt of fee / commission income has been accepted to be at arm’s length. Hence, there is no question of further fee that is required for the assessee in respect of continuing ECBs. - No additions.
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