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...
Scope of SCN - lack of jurisdiction - it is submitted that, passing orders, disposing of the SCNs in a hurry only to pre-empt today's hearing and to present the Court with a fait accompli - The Court finds this is to be extraordinary. It unmistakably reflects the anxiety of the Officer in question who has issued the SCNs to proceed to dispose them of hurriedly and thus preempt the hearing before this Court - This Court would not like to presume that statutory authorities would be unmindful of their statutory responsibilities of determining every SCN in an objective and impartial manner on the basis of the facts presented before them, addressing all the legal submissions made in response to the SCN. - HC
Scope of SCN - lack of jurisdiction - it is submitted that, passing orders, disposing of the SCNs in a hurry only to pre-empt today's hearing and to present the Court with a fait accompli - The Court finds this is to be extraordinary. It unmistakably reflects the anxiety of the Officer in question who has issued the SCNs to proceed to dispose them of hurriedly and thus preempt the hearing before this Court - This Court would not like to presume that statutory authorities would be unmindful of their statutory responsibilities of determining every SCN in an objective and impartial manner on the basis of the facts presented before them, addressing all the legal submissions made in response to the SCN. - HC
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