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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TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not have any relevance. Associated Enterprises have made the borrowing in foreign jurisdiction, therefore, the cost of borrowing of the assessee in India cannot be held to be an internal CUP. - order of the ld. AO to charge interest on the advances given to foreign associate enterprise at Libor plus 200 basis point confirmed - AT
TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not have any relevance. Associated Enterprises have made the borrowing in foreign jurisdiction, therefore, the cost of borrowing of the assessee in India cannot be held to be an internal CUP. - order of the ld. AO to charge interest on the advances given to foreign associate enterprise at Libor plus 200 basis point confirmed - AT
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