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 quashed the impugned order dated 10.02.2025 and remitted the matter to the respondent with directions to pass a fresh order levying a reduced penalty under section 47(2) after issuing due notice to the petitioner. The court observed the petitioner failed to furnish the annual return (GSTR-9) for FY 2020-21 beyond the statutory window under section 44(2) and Rule 80(1A), but treated the late-fee/demand under section 47(2) as venial, noting the petitioner's willingness to file the return. The petition is disposed of with the respondent directed to re-determine penalty quantum consistent with these observations.
The HC quashed the impugned order dated 10.02.2025 and remitted the matter to the respondent with directions to pass a fresh order levying a reduced penalty under section 47(2) after issuing due notice to the petitioner. The court observed the petitioner failed to furnish the annual return (GSTR-9) for FY 2020-21 beyond the statutory window under section 44(2) and Rule 80(1A), but treated the late-fee/demand under section 47(2) as venial, noting the petitioner's willingness to file the return. The petition is disposed of with the respondent directed to re-determine penalty quantum consistent with these observations.
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