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...
TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment determined by the learned transfer-pricing officer in the remand report deserves to be accepted. Accordingly we direct the learned AO to restrict the addition on account of arm’s-length price of the international transaction of receipt of royalty income from Vietnam associated enterprise of the assessee - AT
TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment determined by the learned transfer-pricing officer in the remand report deserves to be accepted. Accordingly we direct the learned AO to restrict the addition on account of arm’s-length price of the international transaction of receipt of royalty income from Vietnam associated enterprise of the assessee - AT
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