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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Extended limitation under Section 74 of the CGST Act for fraud, wilful misstatement or suppression of facts requires the show-cause notice itself to disclose specific allegations and the factual basis supporting that inference. A bare reference to "fraud or concealment of facts" does not establish a valid basis for invoking the extended period, and deficiencies in the notice cannot be cured through a counter affidavit. Where the ordinary limitation period has expired, including applicable exclusion of time, an unsupported invocation of extended limitation renders the notice unsustainable. Further proceedings based on such a notice cannot continue.
Extended limitation under Section 74 of the CGST Act for fraud, wilful misstatement or suppression of facts requires the show-cause notice itself to disclose specific allegations and the factual basis supporting that inference. A bare reference to "fraud or concealment of facts" does not establish a valid basis for invoking the extended period, and deficiencies in the notice cannot be cured through a counter affidavit. Where the ordinary limitation period has expired, including applicable exclusion of time, an unsupported invocation of extended limitation renders the notice unsustainable. Further proceedings based on such a notice cannot continue.
Note: It is a system-generated summary and is for quick reference only.
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