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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Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question of fact - CIT directed to determine income on account of receipts from provision of software enabled solutions to the oil and gas industry along with providing annual maintenance services of the software - CIT to assess the Petitioner’s income and tax payable thereon by first determining the nature of the income/receipts in the hands of the assessee in light of the observations made in this judgment. - HC
Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question of fact - CIT directed to determine income on account of receipts from provision of software enabled solutions to the oil and gas industry along with providing annual maintenance services of the software - CIT to assess the Petitioner’s income and tax payable thereon by first determining the nature of the income/receipts in the hands of the assessee in light of the observations made in this judgment. - HC
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