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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Compulsory scrutiny - AO Jurisdiction and authority to take up the case for compulsory scrutiny - Since the conditions as prescribed in Clause D of para 3 of the instruction no. 13/2013 are not satisfied therefore, the Assessing Officer was not having the jurisdiction and authority to take up the case for compulsory scrutiny. Accordingly, the initiation of the compulsory scrutiny proceedings by issuing the notice under section 143(2) dated 11.6.2013 is invalid and consequently the assessment framed by the Assessing Officer is vitiated as invalid in law. - AT
Compulsory scrutiny - AO Jurisdiction and authority to take up the case for compulsory scrutiny - Since the conditions as prescribed in Clause D of para 3 of the instruction no. 13/2013 are not satisfied therefore, the Assessing Officer was not having the jurisdiction and authority to take up the case for compulsory scrutiny. Accordingly, the initiation of the compulsory scrutiny proceedings by issuing the notice under section 143(2) dated 11.6.2013 is invalid and consequently the assessment framed by the Assessing Officer is vitiated as invalid in law. - AT
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