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...
Demand u/s 201(1) with interest u/s 201(1A) - non deduction of TDS on the interest paid to HUDCO - minor delay in submitting the declaration that the payee (HUDCO) has paid tax on such interest - When there was no dispute about such a declaration being filed in a prescribed format and there was no dispute about the genuineness of such declaration, mere minor delay in filing the said declaration would not defeat the very claim. - AT
Demand u/s 201(1) with interest u/s 201(1A) - non deduction of TDS on the interest paid to HUDCO - minor delay in submitting the declaration that the payee (HUDCO) has paid tax on such interest - When there was no dispute about such a declaration being filed in a prescribed format and there was no dispute about the genuineness of such declaration, mere minor delay in filing the said declaration would not defeat the very claim. - AT
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