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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Rejection of declaration filed under the amnesty scheme - SVLDRS - SVLDR is a beneficial scheme and purposive interpretation of its terms is desirable - The declarants are thus expected to come clean in order take its benefit. During investigation, Petitioner only admitted Service Tax liability and did not make any disclosure with respect to the other tax dues and as a result whereof, after investigation, Respondents have issued the demand-cum show cause notice - This SCN would have to be adjudicated in entirety and cannot be done in a piecemeal manner - Petitioner's declaration was rightly rejected - HC
Rejection of declaration filed under the amnesty scheme - SVLDRS - SVLDR is a beneficial scheme and purposive interpretation of its terms is desirable - The declarants are thus expected to come clean in order take its benefit. During investigation, Petitioner only admitted Service Tax liability and did not make any disclosure with respect to the other tax dues and as a result whereof, after investigation, Respondents have issued the demand-cum show cause notice - This SCN would have to be adjudicated in entirety and cannot be done in a piecemeal manner - Petitioner's declaration was rightly rejected - HC
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