Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT
TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT
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