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TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Additional evidence supporting guest-house expenditure and the applicable head of income cannot be rejected solely for want of a separate Rule 46A application without independent merits adjudication; the dispute was remitted for fresh de novo consideration after hearing. The challenge to the appellate order issued after the assessee's death failed because the record did not show notices to a deceased person or that the appellate authority had been informed of the death. Objections to penalty initiation were premature absent a penalty order. Interest under sections 234A and 234B was treated as automatic, compensatory and consequential, for examination while giving effect to the order.
Additional evidence supporting guest-house expenditure and the applicable head of income cannot be rejected solely for want of a separate Rule 46A application without independent merits adjudication; the dispute was remitted for fresh de novo consideration after hearing. The challenge to the appellate order issued after the assessee's death failed because the record did not show notices to a deceased person or that the appellate authority had been informed of the death. Objections to penalty initiation were premature absent a penalty order. Interest under sections 234A and 234B was treated as automatic, compensatory and consequential, for examination while giving effect to the order.
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