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 multiple tax periods/financial years could be clubbed in a single/composite show cause notice under Sections 73/74 of the CGST/KGST Act. Relying on its earlier precedent, the Court held that such clubbing/consolidation/bunching is illegal, invalid, impermissible, and without jurisdiction, being contrary to the CGST/KGST Act; consequently, the composite show cause notice and its addendum were quashed. All consequential communications, the subsequent orders including the order-in-original, and all further proceedings pursuant to the impugned notice were also quashed, and the writ petition was allowed. - HC
The dominant issue was whether multiple tax periods/financial years could be clubbed in a single/composite show cause notice under Sections 73/74 of the CGST/KGST Act. Relying on its earlier precedent, the Court held that such clubbing/consolidation/bunching is illegal, invalid, impermissible, and without jurisdiction, being contrary to the CGST/KGST Act; consequently, the composite show cause notice and its addendum were quashed. All consequential communications, the subsequent orders including the order-in-original, and all further proceedings pursuant to the impugned notice were also quashed, and the writ petition was allowed. - HC
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