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...
Scope of SCN - The argument that the original authority has confirmed a higher amount on grounds which are not alleged in the SCN and has thus traversed beyond the SCN is not without substance. There is also no evidence available from the impugned order or from the records that SCN and the OIO have been served on the appellant. The said plea has been put forward by the appellant from the very beginning of the litigation. - AT
Scope of SCN - The argument that the original authority has confirmed a higher amount on grounds which are not alleged in the SCN and has thus traversed beyond the SCN is not without substance. There is also no evidence available from the impugned order or from the records that SCN and the OIO have been served on the appellant. The said plea has been put forward by the appellant from the very beginning of the litigation. - AT
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