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...
Faceless assessment procedure requires a meaningful opportunity of personal hearing where sought, including access to video-conference facilities. The text records a prima facie concern that, after the assessee could not access the video-conference link because of a technical glitch, no further personal-hearing opportunity was provided before the assessment order was issued. It identifies possible non-compliance with the hearing procedure under the faceless assessment framework. The Revenue was given time to verify whether the final additions exceeded those proposed in the show-cause notice and whether video-conference access had been provided during the relevant period; the matter was listed for further instructions.
Faceless assessment procedure requires a meaningful opportunity of personal hearing where sought, including access to video-conference facilities. The text records a prima facie concern that, after the assessee could not access the video-conference link because of a technical glitch, no further personal-hearing opportunity was provided before the assessment order was issued. It identifies possible non-compliance with the hearing procedure under the faceless assessment framework. The Revenue was given time to verify whether the final additions exceeded those proposed in the show-cause notice and whether video-conference access had been provided during the relevant period; the matter was listed for further instructions.
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