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...
Offence u/s 276C(2) r/w 278B - Wilful attempt to evade tax, etc - Conduct of the petitioners itself would indicate that it was a case of delayed payment of tax or deferred payment. The tax along with interest and penalty was accepted by the department without any reservations. Such delay in the payment will not amount to willful attempt to evade tax - the continuation of the proceedings against the petitioners would an abuse of process of the Court. - HC
Offence u/s 276C(2) r/w 278B - Wilful attempt to evade tax, etc - Conduct of the petitioners itself would indicate that it was a case of delayed payment of tax or deferred payment. The tax along with interest and penalty was accepted by the department without any reservations. Such delay in the payment will not amount to willful attempt to evade tax - the continuation of the proceedings against the petitioners would an abuse of process of the Court. - HC
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