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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Scope of the "Point of difference" - Divergent views of the members of tribunal - matter referred to third member - appellant sight that more points to be included in the reference made to third member - this `Tribunal’ is of the earnest opinion that the said `impugned order’ cannot be termed by no stretch of imagination as `an Order’, in the teeth of culling out of `the point of difference’ (between the `Hon’ble Two Members of the Tribunal’) and formulating the same, is just a `Ministerial Act’ (`on Administrative Side’) of the `Tribunal’, without an entry upon any `Adjudicatory Process’. - No appeal is maintainable against the same - AT
Scope of the "Point of difference" - Divergent views of the members of tribunal - matter referred to third member - appellant sight that more points to be included in the reference made to third member - this `Tribunal’ is of the earnest opinion that the said `impugned order’ cannot be termed by no stretch of imagination as `an Order’, in the teeth of culling out of `the point of difference’ (between the `Hon’ble Two Members of the Tribunal’) and formulating the same, is just a `Ministerial Act’ (`on Administrative Side’) of the `Tribunal’, without an entry upon any `Adjudicatory Process’. - No appeal is maintainable against the same - AT
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