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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The HC granted partial relief to the petitioner by allowing operation of the frozen bank account, subject to the condition that the existing balance exceeding Rs. 6.00 Crores remain untouched until the CIT(A) disposes of the appeal within six weeks. The petitioner may deposit additional funds and withdraw those amounts for business purposes. The court directed the CIT(A) to expeditiously adjudicate the appeal in accordance with law, balancing the petitioner's operational needs against the Revenue's claim. This interim order preserves the status quo on the substantial existing funds while enabling limited liquidity to prevent business paralysis.
The HC granted partial relief to the petitioner by allowing operation of the frozen bank account, subject to the condition that the existing balance exceeding Rs. 6.00 Crores remain untouched until the CIT(A) disposes of the appeal within six weeks. The petitioner may deposit additional funds and withdraw those amounts for business purposes. The court directed the CIT(A) to expeditiously adjudicate the appeal in accordance with law, balancing the petitioner's operational needs against the Revenue's claim. This interim order preserves the status quo on the substantial existing funds while enabling limited liquidity to prevent business paralysis.
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