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...
Valuation of goods - related party transaction - The only case of the department rests on two counts: (i) the appellant has shown three of said companies as its ‘Associated and Joint ventures’ in their balance sheet; and (ii) The directors of appellants are the directors in either of the three undertakings - In the present case, it is observed that the Department has not produced any evidence of proving the mutuality of interest of three other companies with the appellant. - Demand set aside - AT
Valuation of goods - related party transaction - The only case of the department rests on two counts: (i) the appellant has shown three of said companies as its ‘Associated and Joint ventures’ in their balance sheet; and (ii) The directors of appellants are the directors in either of the three undertakings - In the present case, it is observed that the Department has not produced any evidence of proving the mutuality of interest of three other companies with the appellant. - Demand set aside - AT
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