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...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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HC dismissed the appeal, finding no substantial question of law regarding invocation of the extended five-year limitation period under Section 73(1) of Finance Act, 1994. The court upheld CESTAT's determination that the respondent's actions were based on bona fide belief rather than wilful misstatement or fraud. Though the Commissioner issued a composite show cause notice covering 2004-2009, the court declined to interfere with CESTAT's order, particularly regarding the period after the August 23, 2007 master circular, as no fraudulent intent was established to justify extending the limitation period.
HC dismissed the appeal, finding no substantial question of law regarding invocation of the extended five-year limitation period under Section 73(1) of Finance Act, 1994. The court upheld CESTAT's determination that the respondent's actions were based on bona fide belief rather than wilful misstatement or fraud. Though the Commissioner issued a composite show cause notice covering 2004-2009, the court declined to interfere with CESTAT's order, particularly regarding the period after the August 23, 2007 master circular, as no fraudulent intent was established to justify extending the limitation period.
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