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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Refund of accumulated credit - ascertainment of eligible refund under Rule 5 - In both the numerator and denominator, the amount of export turnover have to be considered (i.e. same figure ) when there is no domestic services rendered by the assessee appellant inasmuch as the “value of all other services” would be ‘NIL’ in the given case. There is no reason to consider the aggregate of the value of export turnover payment of which has been received and those for which payment has not been received, since not required in the prescribed formula - AT
Refund of accumulated credit - ascertainment of eligible refund under Rule 5 - In both the numerator and denominator, the amount of export turnover have to be considered (i.e. same figure ) when there is no domestic services rendered by the assessee appellant inasmuch as the “value of all other services” would be ‘NIL’ in the given case. There is no reason to consider the aggregate of the value of export turnover payment of which has been received and those for which payment has not been received, since not required in the prescribed formula - AT
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