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...
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
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