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...
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Entertainability of petition challenging show cause notice for recovery of taxes, determination of value of supply u/s 15(3)(b) of CGST Act. Allegations of suppressing facts, misstatement regarding non-furnishing outward supplies u/s 37, intention to evade GST from July 2017 to March 2022. Invocation of extended period of limitation based on suppression, misstatement with intent to evade GST. Adjudication on factual issues of suppression, misstatement, onus of proof u/s 15(3)(b) cannot be undertaken in writ jurisdiction. No challenge to circular in prayer. Petition dismissed, time granted till 15 December 2024 to file reply. Personal hearing, reasoned order by 31 January 2025 directed.
Entertainability of petition challenging show cause notice for recovery of taxes, determination of value of supply u/s 15(3)(b) of CGST Act. Allegations of suppressing facts, misstatement regarding non-furnishing outward supplies u/s 37, intention to evade GST from July 2017 to March 2022. Invocation of extended period of limitation based on suppression, misstatement with intent to evade GST. Adjudication on factual issues of suppression, misstatement, onus of proof u/s 15(3)(b) cannot be undertaken in writ jurisdiction. No challenge to circular in prayer. Petition dismissed, time granted till 15 December 2024 to file reply. Personal hearing, reasoned order by 31 January 2025 directed.
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