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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The Delhi High Court dismissed the appeal challenging the findings of the Single Judge on the limitation period for a suit. The appellant did not dispute the legal findings that the deposit of TDS triggers a fresh limitation period u/s 19 of the Act of 1963. The appellant raised a factual dispute regarding a transaction reflected in the TDS certificate, claiming it pertained to a separate transaction. The court rejected this claim as it was not raised before the Single Judge. The court held that the Single Judge's conclusion based on the TDS certificate was in line with the evidence and law. The court dismissed the appeal and pending applications, affirming the Single Judge's decision on the limitation issue.
The Delhi High Court dismissed the appeal challenging the findings of the Single Judge on the limitation period for a suit. The appellant did not dispute the legal findings that the deposit of TDS triggers a fresh limitation period u/s 19 of the Act of 1963. The appellant raised a factual dispute regarding a transaction reflected in the TDS certificate, claiming it pertained to a separate transaction. The court rejected this claim as it was not raised before the Single Judge. The court held that the Single Judge's conclusion based on the TDS certificate was in line with the evidence and law. The court dismissed the appeal and pending applications, affirming the Single Judge's decision on the limitation issue.
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