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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Disallowance of swap contract loss - whether the loss is not real but a notional loss for the reason that there was no actual transaction carried out by the assessee - We find no infirmity in the impugned order of the CIT(A) allowing the claim of the assessee for deduction on account of Mark-to Market Exchange Loss in respect of Foreign Currency Derivatives Contracts and upholding the same, we dismiss of the Revenue’s appeal. - AT
Disallowance of swap contract loss - whether the loss is not real but a notional loss for the reason that there was no actual transaction carried out by the assessee - We find no infirmity in the impugned order of the CIT(A) allowing the claim of the assessee for deduction on account of Mark-to Market Exchange Loss in respect of Foreign Currency Derivatives Contracts and upholding the same, we dismiss of the Revenue’s appeal. - AT
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