Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
MAT computation u/s 115JB - addition of the amortization of Intangibles - The intangible assets are acquired and owned by the assessee company pursuant to the approved Scheme.- There is perpetual and irrevocable transfer of the intangible assets such as Trade Marks to the assessee company. - The contention of the Ld. AO that there was no transfer of ownership of the assets to the assessee company is incorrect - Addition deleted - AT
MAT computation u/s 115JB - addition of the amortization of Intangibles - The intangible assets are acquired and owned by the assessee company pursuant to the approved Scheme.- There is perpetual and irrevocable transfer of the intangible assets such as Trade Marks to the assessee company. - The contention of the Ld. AO that there was no transfer of ownership of the assets to the assessee company is incorrect - Addition deleted - AT
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