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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Disallowance u/s. 40A(3) - business expediency in payment of cash towards genuine transaction - The contention of the assessee from the day one is that the sellers demanded the assessee to pay in cash which is part and parcel of total sale consideration.There is no dispute with regard to identification of the sellers as well as their confirmations in respect of payment in cash from the assessee. - The sellers also admitted the payment of cash before the registering authority under due process. - Additions deleted - AT
Disallowance u/s. 40A(3) - business expediency in payment of cash towards genuine transaction - The contention of the assessee from the day one is that the sellers demanded the assessee to pay in cash which is part and parcel of total sale consideration.There is no dispute with regard to identification of the sellers as well as their confirmations in respect of payment in cash from the assessee. - The sellers also admitted the payment of cash before the registering authority under due process. - Additions deleted - AT
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