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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Error apparent on record rectified by allowing Revenue's appeal instead of wrongly dismissing it, as logical conclusion of upholding Revenue's contentions. Rectification limited to correcting error on record, not re-hearing matter. Apex Court's guidelines on rectifying apparent errors followed. Request to reconsider monetary limits post-disposal not entertained, as it would reopen decided matters. CESTAT's final order dated 18.03.2024 disposing appeal upheld, no other errors found.
Error apparent on record rectified by allowing Revenue's appeal instead of wrongly dismissing it, as logical conclusion of upholding Revenue's contentions. Rectification limited to correcting error on record, not re-hearing matter. Apex Court's guidelines on rectifying apparent errors followed. Request to reconsider monetary limits post-disposal not entertained, as it would reopen decided matters. CESTAT's final order dated 18.03.2024 disposing appeal upheld, no other errors found.
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