Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
A scrutiny notice need not conform to a CBDT-prescribed format where the Income-tax Act and Rules do not mandate that format. The essential requirements are timely issue by the competent authority, notice that the return was selected for scrutiny, and an opportunity to provide supporting evidence. Limited, Complete and Manual Scrutiny are administrative classifications, and failure to disclose the category is not a jurisdictional defect. Although CBDT instructions bind departmental authorities administratively, their breach invalidates proceedings only where they supplement a statutory condition precedent or cause prejudice. A curable format irregularity is protected by section 292B when the notice serves its statutory purpose and no prejudice is shown.
A scrutiny notice need not conform to a CBDT-prescribed format where the Income-tax Act and Rules do not mandate that format. The essential requirements are timely issue by the competent authority, notice that the return was selected for scrutiny, and an opportunity to provide supporting evidence. Limited, Complete and Manual Scrutiny are administrative classifications, and failure to disclose the category is not a jurisdictional defect. Although CBDT instructions bind departmental authorities administratively, their breach invalidates proceedings only where they supplement a statutory condition precedent or cause prejudice. A curable format irregularity is protected by section 292B when the notice serves its statutory purpose and no prejudice is shown.
Note: It is a system-generated summary and is for quick reference only.
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