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...
Smuggling - foreign currency - illicit export of currency - beneficial owners - The actual owner of the foreign currency having been identified, the concept of ‘beneficial owner’ does not arise. The Commissioner (Appeals), therefore, was not justified in reversing the finding recorded by the Additional Commissioner that the concept of ‘beneficial owner’ would not arise in the facts and circumstances of the case. - AT
Smuggling - foreign currency - illicit export of currency - beneficial owners - The actual owner of the foreign currency having been identified, the concept of ‘beneficial owner’ does not arise. The Commissioner (Appeals), therefore, was not justified in reversing the finding recorded by the Additional Commissioner that the concept of ‘beneficial owner’ would not arise in the facts and circumstances of the case. - AT
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