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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring benchmarking and such a treatment is bad under law and working capital adjustment would take into account the impact of outstanding receivables and no need to impute any interest on receivables - the interest shall be charged only at 6% p.a. in respect of the receivables outstanding for more than 30 days. - AT
TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring benchmarking and such a treatment is bad under law and working capital adjustment would take into account the impact of outstanding receivables and no need to impute any interest on receivables - the interest shall be charged only at 6% p.a. in respect of the receivables outstanding for more than 30 days. - AT
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