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 upheld that consolidation of a single show cause notice for multiple assessment years is permissible where the primary allegation is fraudulent availing of input tax credit, as alleged against the Petitioner concerning ITC exceeding Rs. 41 crores. Noting that the primary legal issue aligns with precedent, the Court declined extraordinary relief and disposed of the petition, observing that the impugned order is appealable under Section 107, CGST Act, 2017. The Petitioner was afforded liberty to institute an appeal by 30 September 2025 subject to filing the statutory appeal and making the requisite pre-deposits as mandated by the appellate provisions.
The HC upheld that consolidation of a single show cause notice for multiple assessment years is permissible where the primary allegation is fraudulent availing of input tax credit, as alleged against the Petitioner concerning ITC exceeding Rs. 41 crores. Noting that the primary legal issue aligns with precedent, the Court declined extraordinary relief and disposed of the petition, observing that the impugned order is appealable under Section 107, CGST Act, 2017. The Petitioner was afforded liberty to institute an appeal by 30 September 2025 subject to filing the statutory appeal and making the requisite pre-deposits as mandated by the appellate provisions.
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