Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Faceless assessment procedure requires a meaningful opportunity of personal hearing where sought, including access to video-conference facilities. The text records a prima facie concern that, after the assessee could not access the video-conference link because of a technical glitch, no further personal-hearing opportunity was provided before the assessment order was issued. It identifies possible non-compliance with the hearing procedure under the faceless assessment framework. The Revenue was given time to verify whether the final additions exceeded those proposed in the show-cause notice and whether video-conference access had been provided during the relevant period; the matter was listed for further instructions.
Faceless assessment procedure requires a meaningful opportunity of personal hearing where sought, including access to video-conference facilities. The text records a prima facie concern that, after the assessee could not access the video-conference link because of a technical glitch, no further personal-hearing opportunity was provided before the assessment order was issued. It identifies possible non-compliance with the hearing procedure under the faceless assessment framework. The Revenue was given time to verify whether the final additions exceeded those proposed in the show-cause notice and whether video-conference access had been provided during the relevant period; the matter was listed for further instructions.
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