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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Disallowance u/s 14A r.w.r. 8D - expenditure incurred to earn exempt income - the disallowance u/s 14A on account of such expenses is liable to be worked out by applying the formula given in rule 8D(2)(iii) of the Rules, the basis given therein cannot be altered or changed as sought by assessee, unless and until the basis so given in the formula is found to be patently untenable in the facts and circumstances of a particular case - AT
Disallowance u/s 14A r.w.r. 8D - expenditure incurred to earn exempt income - the disallowance u/s 14A on account of such expenses is liable to be worked out by applying the formula given in rule 8D(2)(iii) of the Rules, the basis given therein cannot be altered or changed as sought by assessee, unless and until the basis so given in the formula is found to be patently untenable in the facts and circumstances of a particular case - AT
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