Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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CESTAT allowed the refund application, holding that the limitation period was validly extended by Supreme Court's COVID-19 order. The appellant's refund application filed on 12.04.2022 was deemed timely, as the period from 15.03.2020 to 28.02.2022 was explicitly excluded from limitation calculations. The tribunal criticized the Commissioner (Appeals) for being unaware of the Supreme Court's directive, ultimately dismissing the lower court's orders and granting the appellant's appeals.
CESTAT allowed the refund application, holding that the limitation period was validly extended by Supreme Court's COVID-19 order. The appellant's refund application filed on 12.04.2022 was deemed timely, as the period from 15.03.2020 to 28.02.2022 was explicitly excluded from limitation calculations. The tribunal criticized the Commissioner (Appeals) for being unaware of the Supreme Court's directive, ultimately dismissing the lower court's orders and granting the appellant's appeals.
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