Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT
Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT
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