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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HC held that the respondent's action blocking the petitioner's Electronic Credit Ledger ITC was invalid and set aside; the petition allowed. The Court ruled that Rule 86A(1) U.P.G.S.T. Rules 2017 mandates that any "reasons to believe" for blocking ITC must be recorded in writing and must arise from material on record demonstrating a nexus to the belief. Although the exercise may be ex parte, the statutory requirement to record reasons in writing is mandatory; mere suspicion or change of opinion without material justification is insufficient to interrupt the ITC chain. Accordingly the e-mail blocking the petitioner's ITC was quashed.
HC held that the respondent's action blocking the petitioner's Electronic Credit Ledger ITC was invalid and set aside; the petition allowed. The Court ruled that Rule 86A(1) U.P.G.S.T. Rules 2017 mandates that any "reasons to believe" for blocking ITC must be recorded in writing and must arise from material on record demonstrating a nexus to the belief. Although the exercise may be ex parte, the statutory requirement to record reasons in writing is mandatory; mere suspicion or change of opinion without material justification is insufficient to interrupt the ITC chain. Accordingly the e-mail blocking the petitioner's ITC was quashed.
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