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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TDS u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT
TDS u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT
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