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...
Association of persons (AOP) - Consortium - Appellant No.1 is a member of AOP or not - There is no force in the contention of Appellant No.1 that due to absence of right to any profits of the consortium, the Appellant No.1 cannot be deemed to be a member of the AOP. Indeed, in the return filed, the share of Appellant No.1 is shown to be 0%. Indeed in the addendum, there is division of work, but, that is only a mode of completing the ‘Project’. As far as sharing of profits is concerned Deepali Designs, who is Appellant No.1 before us, had agreed by virtue of sub-clause (3) of Clause 2 of the addendum, to forego 23% of its gross revenue to PHKL. - AT
Association of persons (AOP) - Consortium - Appellant No.1 is a member of AOP or not - There is no force in the contention of Appellant No.1 that due to absence of right to any profits of the consortium, the Appellant No.1 cannot be deemed to be a member of the AOP. Indeed, in the return filed, the share of Appellant No.1 is shown to be 0%. Indeed in the addendum, there is division of work, but, that is only a mode of completing the ‘Project’. As far as sharing of profits is concerned Deepali Designs, who is Appellant No.1 before us, had agreed by virtue of sub-clause (3) of Clause 2 of the addendum, to forego 23% of its gross revenue to PHKL. - AT
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