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...
Rectification of mistake u/s 154 - the explanation of payments on Holidays appears highly doubtful but however such inference cannot be taken in the realm of obvious mistake. Section 154 has no application to gauge the purported mala fides in explanation offered by the Assessee behind such transaction. - AT
Rectification of mistake u/s 154 - the explanation of payments on Holidays appears highly doubtful but however such inference cannot be taken in the realm of obvious mistake. Section 154 has no application to gauge the purported mala fides in explanation offered by the Assessee behind such transaction. - AT
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