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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TDS u/s 195 - Disallowance of commission, brokerage and discount expenses - in the instant case where the overseas agents were paid commission for securing order etc., and such services were utilised for the purpose of making or earning income from a source outside India, the assessee is under no obligation to apply with provisions of Section 195 for the reasons that commission to such overseas agents are not taxable under the Act. - Additions deleted - AT
TDS u/s 195 - Disallowance of commission, brokerage and discount expenses - in the instant case where the overseas agents were paid commission for securing order etc., and such services were utilised for the purpose of making or earning income from a source outside India, the assessee is under no obligation to apply with provisions of Section 195 for the reasons that commission to such overseas agents are not taxable under the Act. - Additions deleted - AT
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