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...
The dominant issue was whether the tax authority should be directed to act on a pending refund application and consider interest and penalty. The court held that the authority must decide the refund application in accordance with law, specifically taking into account the claim for refund along with applicable interest, and bearing in mind binding precedents on such refund claims. Consequently, the authority was directed to consider, process, and pass appropriate orders on the refund application within four months from receipt of the order, and the writ petition was disposed of. - HC
The dominant issue was whether the tax authority should be directed to act on a pending refund application and consider interest and penalty. The court held that the authority must decide the refund application in accordance with law, specifically taking into account the claim for refund along with applicable interest, and bearing in mind binding precedents on such refund claims. Consequently, the authority was directed to consider, process, and pass appropriate orders on the refund application within four months from receipt of the order, and the writ petition was disposed of. - HC
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