Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
TP Adjustment - bilateral Advance Pricing Agreement (APA) between India and the USA - modified return of income - The ITAT found merit in the assessee's argument regarding the APA between India and the USA, agreeing that the methodology used for the transactions had been agreed upon. It directed the Assessing Officer to consider the modified return of income in light of the APA and decide the issue afresh after affording reasonable opportunity to the assessee. The court allowed this ground for statistical purposes.
TP Adjustment - bilateral Advance Pricing Agreement (APA) between India and the USA - modified return of income - The ITAT found merit in the assessee's argument regarding the APA between India and the USA, agreeing that the methodology used for the transactions had been agreed upon. It directed the Assessing Officer to consider the modified return of income in light of the APA and decide the issue afresh after affording reasonable opportunity to the assessee. The court allowed this ground for statistical purposes.
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