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...
Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that these issues were adjudicated in favor of the assessee in previous years, relying on ITAT and High Court decisions. The adjustments made by the AO were not upheld, and the tribunal directed the deletion of these adjustments, affirming the assessee's approach to charging 1% corporate guarantee fees and handling of OCL and reimbursement of expenses as per the precedents.
Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that these issues were adjudicated in favor of the assessee in previous years, relying on ITAT and High Court decisions. The adjustments made by the AO were not upheld, and the tribunal directed the deletion of these adjustments, affirming the assessee's approach to charging 1% corporate guarantee fees and handling of OCL and reimbursement of expenses as per the precedents.
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