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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Central GST authorities issued summons following a search operation, despite ongoing State GST proceedings. The HC held that statutory prohibition against parallel proceedings under Sections 73 and 74 specifically pertains to assessment proceedings, not investigative actions. Search-based summons are distinct from assessment proceedings as they aim to gather information potentially unavailable during original assessment. The Court distinguished between assessment proceedings and investigative measures, noting that Section 6(2)(b) applies to interrelated events in a particular chain. Since the search occurred after previous assessments, it constitutes a separate proceeding. The summons were deemed valid as investigative tools that may lead to future proceedings. Petition challenging the validity of CGST summons dismissed.
Central GST authorities issued summons following a search operation, despite ongoing State GST proceedings. The HC held that statutory prohibition against parallel proceedings under Sections 73 and 74 specifically pertains to assessment proceedings, not investigative actions. Search-based summons are distinct from assessment proceedings as they aim to gather information potentially unavailable during original assessment. The Court distinguished between assessment proceedings and investigative measures, noting that Section 6(2)(b) applies to interrelated events in a particular chain. Since the search occurred after previous assessments, it constitutes a separate proceeding. The summons were deemed valid as investigative tools that may lead to future proceedings. Petition challenging the validity of CGST summons dismissed.
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