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...
In an anti-profiteering inquiry under section 171, tax reduction and input tax credit issues must still be tested against evidence that prices may also be affected by market forces and higher input costs. The Tribunal accepted that any presumption of profiteering is rebuttable and must yield to clear evidence. Because the DGAP acknowledged the respondent's documents but did not meaningfully reconsider them, the report was found unsustainable. The matter was remanded for a fresh investigation from the beginning under Rule 133(4), with liberty to both sides to place further material.
In an anti-profiteering inquiry under section 171, tax reduction and input tax credit issues must still be tested against evidence that prices may also be affected by market forces and higher input costs. The Tribunal accepted that any presumption of profiteering is rebuttable and must yield to clear evidence. Because the DGAP acknowledged the respondent's documents but did not meaningfully reconsider them, the report was found unsustainable. The matter was remanded for a fresh investigation from the beginning under Rule 133(4), with liberty to both sides to place further material.
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