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...
A consolidated demand-cum-show cause notice covering multiple financial years is not barred under the CGST Act, whether issued under the ordinary demand provision or the provision concerning fraud, wilful misstatement or suppression. The article notes that the selection of the latter provision depends on factual findings about conduct intended to evade tax and ordinarily cannot be decided in writ proceedings at the notice stage; affected persons must respond before the Proper Officer and use statutory appellate remedies. Where a fresh reply opportunity is granted, adjudication is restored to the notice stage, with the court-directed period excluded when calculating the time available for adjudication.
A consolidated demand-cum-show cause notice covering multiple financial years is not barred under the CGST Act, whether issued under the ordinary demand provision or the provision concerning fraud, wilful misstatement or suppression. The article notes that the selection of the latter provision depends on factual findings about conduct intended to evade tax and ordinarily cannot be decided in writ proceedings at the notice stage; affected persons must respond before the Proper Officer and use statutory appellate remedies. Where a fresh reply opportunity is granted, adjudication is restored to the notice stage, with the court-directed period excluded when calculating the time available for adjudication.
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