Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Rule 26(3) requires electronic GST notices and orders to be authenticated by a digital signature certificate, e-signature or another notified mode; a system-generated reference number establishes issuance and tracking but does not replace authentication. Signature verifies origin, accountability and application of mind, so an unsigned notice or order is treated as non-existent in law. Portal upload under an additional-notices section, without other service, may deny an effective hearing where the taxpayer remains unaware and unrepresented. Such denial breaches natural justice and permits writ intervention despite an appellate remedy. Unsigned proceedings, consequential orders and recovery action may be set aside, with fresh action permissible after authenticated service and a meaningful hearing.
Rule 26(3) requires electronic GST notices and orders to be authenticated by a digital signature certificate, e-signature or another notified mode; a system-generated reference number establishes issuance and tracking but does not replace authentication. Signature verifies origin, accountability and application of mind, so an unsigned notice or order is treated as non-existent in law. Portal upload under an additional-notices section, without other service, may deny an effective hearing where the taxpayer remains unaware and unrepresented. Such denial breaches natural justice and permits writ intervention despite an appellate remedy. Unsigned proceedings, consequential orders and recovery action may be set aside, with fresh action permissible after authenticated service and a meaningful hearing.
Note: It is a system-generated summary and is for quick reference only.
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