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...
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Communication of recorded reasons is a jurisdictional requirement for reassessment where the assessee requests those reasons. Non-supply prevents the assessee from challenging the reopening and obtaining a speaking decision on objections, thereby breaching principles of natural justice. Reassessment jurisdiction is invalidly assumed when recorded reasons are withheld despite repeated requests, and the reassessment notice and resulting order are liable to be quashed as void.
Communication of recorded reasons is a jurisdictional requirement for reassessment where the assessee requests those reasons. Non-supply prevents the assessee from challenging the reopening and obtaining a speaking decision on objections, thereby breaching principles of natural justice. Reassessment jurisdiction is invalidly assumed when recorded reasons are withheld despite repeated requests, and the reassessment notice and resulting order are liable to be quashed as void.
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