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...
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
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