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 of pre-deposit alongwith interest - CIRP - Approval of Resolution Plan under IBC - Analyzing the insolvency proceedings and the subsequent approval of the resolution plan, the court concluded that the tax liability against the petitioner had been extinguished. Therefore, the rejection of the refund application by the revenue authority was deemed misconstrued and misdirected. The court emphasized the entitlement of the petitioner to the refund, considering the legal precedent established by the Supreme Court regarding resolution plans.
Refund of pre-deposit alongwith interest - CIRP - Approval of Resolution Plan under IBC - Analyzing the insolvency proceedings and the subsequent approval of the resolution plan, the court concluded that the tax liability against the petitioner had been extinguished. Therefore, the rejection of the refund application by the revenue authority was deemed misconstrued and misdirected. The court emphasized the entitlement of the petitioner to the refund, considering the legal precedent established by the Supreme Court regarding resolution plans.
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