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...
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
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