Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.
Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.
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