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 principal issue was whether Section 6(2)(b) CGST permits parallel adjudication by Central and State authorities where proceedings overlap. Relying on the Apex Court's delineation of "initiation of proceedings," "subject-matter," and inter-authority relations, the court held that once one authority first initiates proceedings, subsequent parallel adjudicatory proceedings by the other are barred; investigative steps not amounting to adjudication may continue. Applying that rule, no further adjudication was permitted here; the petitioner was directed to appear before the Central authority and file its response to the show-cause notice by 31.01.2026, and the petition was disposed. - HC
The principal issue was whether Section 6(2)(b) CGST permits parallel adjudication by Central and State authorities where proceedings overlap. Relying on the Apex Court's delineation of "initiation of proceedings," "subject-matter," and inter-authority relations, the court held that once one authority first initiates proceedings, subsequent parallel adjudicatory proceedings by the other are barred; investigative steps not amounting to adjudication may continue. Applying that rule, no further adjudication was permitted here; the petitioner was directed to appear before the Central authority and file its response to the show-cause notice by 31.01.2026, and the petition was disposed. - HC
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