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...
The two appellate authorities have concurrently failed to appreciate not only the fact that the Assessee was entitled to file the 'C' declaration forms even at the appellate stage, which was nothing but continuation of the assessment proceedings, but also, they being the fact finding authority, were entitled to peruse the facts as the assessment authority- HC
The two appellate authorities have concurrently failed to appreciate not only the fact that the Assessee was entitled to file the 'C' declaration forms even at the appellate stage, which was nothing but continuation of the assessment proceedings, but also, they being the fact finding authority, were entitled to peruse the facts as the assessment authority- HC
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