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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TP Adjustment - TPO rejected the ‘entity-level’ benchmarking done by assessee, instead made ‘unit-level’ comparison i.e. PLI of each unit was compared with the PLI of external comparables - 'principle of res judicata' OR ‘principle of consistency' - the uniform rate agreed by assessee with AEs is certainly a rate at entity-level which has no connection or linkage with individual units. - AT
TP Adjustment - TPO rejected the ‘entity-level’ benchmarking done by assessee, instead made ‘unit-level’ comparison i.e. PLI of each unit was compared with the PLI of external comparables - 'principle of res judicata' OR ‘principle of consistency' - the uniform rate agreed by assessee with AEs is certainly a rate at entity-level which has no connection or linkage with individual units. - AT
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