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...
Addition u/s 40(A) - service charges paid to division of the holding company - assessee has been able to demonstrate that the services were charged by SCS to the assessee only by way of reimbursement of costs and no excessive sum was charged to the assessee - AO cannot invoke Sec. 40A(2) without demonstrating excessive & unreasonable expenses. - AT
Addition u/s 40(A) - service charges paid to division of the holding company - assessee has been able to demonstrate that the services were charged by SCS to the assessee only by way of reimbursement of costs and no excessive sum was charged to the assessee - AO cannot invoke Sec. 40A(2) without demonstrating excessive & unreasonable expenses. - AT
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