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 assessee was entitled to deduction u/s 10A despite receiving foreign exchange beyond six months from the end of the previous year, as the Reserve Bank of India, being the competent authority under the Foreign Exchange Management Act, 1999, had granted approval for realization of export proceeds by the assessee. The HC held that such approval met the requirement of Section 10A(3), entitling the assessee to exemption u/s 10A. The decision was rendered in favor of the assessee, in line with the Bombay HC judgment in Morgan Stanley Advantage Services P. Ltd.
The assessee was entitled to deduction u/s 10A despite receiving foreign exchange beyond six months from the end of the previous year, as the Reserve Bank of India, being the competent authority under the Foreign Exchange Management Act, 1999, had granted approval for realization of export proceeds by the assessee. The HC held that such approval met the requirement of Section 10A(3), entitling the assessee to exemption u/s 10A. The decision was rendered in favor of the assessee, in line with the Bombay HC judgment in Morgan Stanley Advantage Services P. Ltd.
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