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...
Impugned proceedings challenged for exceeding scope of show cause notice, non-consideration of submissions during investigation and payments made, gross non-application of mind to material facts, and violation of natural justice principles. Impugned order set aside, petitioner directed to deposit 25% of disputed tax within two weeks, tax already paid adjusted towards deposit. Impugned assessment order treated as show cause notice, petitioner to submit objections with supporting documents within four weeks. Petition disposed of.
Impugned proceedings challenged for exceeding scope of show cause notice, non-consideration of submissions during investigation and payments made, gross non-application of mind to material facts, and violation of natural justice principles. Impugned order set aside, petitioner directed to deposit 25% of disputed tax within two weeks, tax already paid adjusted towards deposit. Impugned assessment order treated as show cause notice, petitioner to submit objections with supporting documents within four weeks. Petition disposed of.
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