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 sets aside the impugned order dated 8/9/2025 that blocked the petitioner's credit ledger account for failure to comply with the procedural mandate of Rule 86-A, noting the absence of contemporaneous reasons and insufficiency of the "reason to believe" standard as applied; the tribunal/authority is also directed to provide a post-decisional hearing which the petitioner is willing to avail. Relief is granted on condition that the petitioner furnishes a bank guarantee from a nationalised bank in the sum of Rs.6,50,00,000. The petition is disposed of accordingly, subject to compliance with the conditional direction and reservation of appropriate administrative follow-up.
The HC sets aside the impugned order dated 8/9/2025 that blocked the petitioner's credit ledger account for failure to comply with the procedural mandate of Rule 86-A, noting the absence of contemporaneous reasons and insufficiency of the "reason to believe" standard as applied; the tribunal/authority is also directed to provide a post-decisional hearing which the petitioner is willing to avail. Relief is granted on condition that the petitioner furnishes a bank guarantee from a nationalised bank in the sum of Rs.6,50,00,000. The petition is disposed of accordingly, subject to compliance with the conditional direction and reservation of appropriate administrative follow-up.
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