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...
Classification of services - IPR service or franchise service? - manufacture and sale of various formulations (fast moving consumer goods) - The arrangement is clearly a typical case of a licensing transaction and is in no way similar to a ‘franchisee’ agreement as understood in the commercial world. - When the services received by the Appellant would merit classification under IPR service, the Appellant would also be entitled to abatement of Service Tax available to a holder of IPR
Classification of services - IPR service or franchise service? - manufacture and sale of various formulations (fast moving consumer goods) - The arrangement is clearly a typical case of a licensing transaction and is in no way similar to a ‘franchisee’ agreement as understood in the commercial world. - When the services received by the Appellant would merit classification under IPR service, the Appellant would also be entitled to abatement of Service Tax available to a holder of IPR
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