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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HC rejected the rectification application, finding no procedural fault by the Respondent-Department. The Court held that the petitioner failed to provide substantive reasoning in the application. While granting time until 10th July, 2025 to file an appeal under Section 107 of CGST Act, the Court left open the issue of notification validity, subject to pending Supreme Court and High Court decisions in related matters. The petitioner was advised to pursue remedies through the appellate authority, with the final determination contingent on ongoing judicial proceedings.
HC rejected the rectification application, finding no procedural fault by the Respondent-Department. The Court held that the petitioner failed to provide substantive reasoning in the application. While granting time until 10th July, 2025 to file an appeal under Section 107 of CGST Act, the Court left open the issue of notification validity, subject to pending Supreme Court and High Court decisions in related matters. The petitioner was advised to pursue remedies through the appellate authority, with the final determination contingent on ongoing judicial proceedings.
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