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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Note: It is a system-generated summary and is for quick reference only.
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