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...
Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a presumption can be drawn that the interest free loans and advances has been given by the assessee out of its own interest free fund available with it. Thus, in such a situation the disallowance of interest u/s 36(1)(iii) is not warranted. - AT
Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a presumption can be drawn that the interest free loans and advances has been given by the assessee out of its own interest free fund available with it. Thus, in such a situation the disallowance of interest u/s 36(1)(iii) is not warranted. - AT
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