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...
HC allowed the petition challenging Rule 86A blocking of Electronic Credit Ledger (ECL), finding the order invalid due to lack of pre-decisional hearing and absence of independent, cogent reasons. The court held that reliance on borrowed satisfaction from enforcement reports without providing specific grounds constitutes an arbitrary action. Respondents were directed to immediately unblock the petitioner's ECL, enabling the petitioner to file returns, thus upholding principles of natural justice and procedural fairness in tax administration.
HC allowed the petition challenging Rule 86A blocking of Electronic Credit Ledger (ECL), finding the order invalid due to lack of pre-decisional hearing and absence of independent, cogent reasons. The court held that reliance on borrowed satisfaction from enforcement reports without providing specific grounds constitutes an arbitrary action. Respondents were directed to immediately unblock the petitioner's ECL, enabling the petitioner to file returns, thus upholding principles of natural justice and procedural fairness in tax administration.
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