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 - subject income being inadvertently shown under the wrong head - Taxability of income in India - The benefit of Article 121 of India-USA Double Taxation Avoidance Agreement [in short, “Indo-USA DTAA”] was available to the respondent/assessee. - Tribunal rightly allowed the claim of assessee - HC
Rectification of mistake u/s 154 - subject income being inadvertently shown under the wrong head - Taxability of income in India - The benefit of Article 121 of India-USA Double Taxation Avoidance Agreement [in short, “Indo-USA DTAA”] was available to the respondent/assessee. - Tribunal rightly allowed the claim of assessee - HC
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