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...
A scrutiny notice under section 143(2) merely informs the assessee that the case has been selected for scrutiny and need not disclose the selection reasons or scope of scrutiny. CBDT and departmental selection guidelines are described as inter-departmental instructions that do not create an assessee right to demand those reasons. Selection may be challenged only on proof of arbitrariness or vendetta. During assessment, the Assessing Officer must issue a specific notice seeking relevant information and documents; the notes state that such a subsequent notice satisfies the assessment-process requirement.
A scrutiny notice under section 143(2) merely informs the assessee that the case has been selected for scrutiny and need not disclose the selection reasons or scope of scrutiny. CBDT and departmental selection guidelines are described as inter-departmental instructions that do not create an assessee right to demand those reasons. Selection may be challenged only on proof of arbitrariness or vendetta. During assessment, the Assessing Officer must issue a specific notice seeking relevant information and documents; the notes state that such a subsequent notice satisfies the assessment-process requirement.
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