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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Determining the jurisdiction of appellate forum - jurisdiction of this Tribunal - The Tribunal refers to the legal precedent established in a Supreme Court case regarding the jurisdiction of appellate forums, emphasizing that the "situs of the assessing officer" is the determining factor regardless of administrative orders. Since the location of the Assessing Officer falls outside the Tribunal's territorial jurisdiction, the appeal is deemed not maintainable. Therefore, the Tribunal dismisses both the Revenue's appeal and the assessee's cross objection, granting them the option to file before the appropriate bench with jurisdiction over the Assessing Officer's location.
Determining the jurisdiction of appellate forum - jurisdiction of this Tribunal - The Tribunal refers to the legal precedent established in a Supreme Court case regarding the jurisdiction of appellate forums, emphasizing that the "situs of the assessing officer" is the determining factor regardless of administrative orders. Since the location of the Assessing Officer falls outside the Tribunal's territorial jurisdiction, the appeal is deemed not maintainable. Therefore, the Tribunal dismisses both the Revenue's appeal and the assessee's cross objection, granting them the option to file before the appropriate bench with jurisdiction over the Assessing Officer's location.
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