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 ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication. Regarding the Transfer Pricing adjustment, the ITAT admitted additional evidence filed by the assessee and directed the TPO to determine the Most Appropriate Method for computing Arm's Length Price after considering the new evidence. Concerning the disallowance of business promotion expenses, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication after the assessee agreed to file evidence.
The ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication. Regarding the Transfer Pricing adjustment, the ITAT admitted additional evidence filed by the assessee and directed the TPO to determine the Most Appropriate Method for computing Arm's Length Price after considering the new evidence. Concerning the disallowance of business promotion expenses, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication after the assessee agreed to file evidence.
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