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 primary issue was whether principles of natural justice were violated by improper service of the show-cause notice and failure to physically serve notice of personal hearing. The court found the record establishes no physical service of the SCN or effective personal-hearing notice, meaning the petitioner was deprived of an opportunity to respond; the court relied on relevant precedents holding similar non-service vitiates proceedings. Consequence: the impugned orders were held to be in violation of natural justice and the petition was partly allowed, setting aside the affected orders. - HC
The primary issue was whether principles of natural justice were violated by improper service of the show-cause notice and failure to physically serve notice of personal hearing. The court found the record establishes no physical service of the SCN or effective personal-hearing notice, meaning the petitioner was deprived of an opportunity to respond; the court relied on relevant precedents holding similar non-service vitiates proceedings. Consequence: the impugned orders were held to be in violation of natural justice and the petition was partly allowed, setting aside the affected orders. - HC
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