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 held that the Show Cause Notices (SCNs) dated 23rd September, 2023 and 4th December, 2023 were not properly served as they were uploaded only on the 'Additional Notices Tab' and were inaccessible to the Petitioner, violating principles of natural justice. Although the SCN dated 27th May, 2024 was properly uploaded, the Petitioner missed it. The impugned orders passed without affording the Petitioner an opportunity to be heard were set aside. The matter was remanded to the Adjudicating Authority for fresh adjudication on merits. The Petitioner was granted time until 31st August, 2025, to file replies to the SCNs. The petition was accordingly disposed of.
The HC held that the Show Cause Notices (SCNs) dated 23rd September, 2023 and 4th December, 2023 were not properly served as they were uploaded only on the 'Additional Notices Tab' and were inaccessible to the Petitioner, violating principles of natural justice. Although the SCN dated 27th May, 2024 was properly uploaded, the Petitioner missed it. The impugned orders passed without affording the Petitioner an opportunity to be heard were set aside. The matter was remanded to the Adjudicating Authority for fresh adjudication on merits. The Petitioner was granted time until 31st August, 2025, to file replies to the SCNs. The petition was accordingly disposed of.
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