Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Faceless assessment procedure requires that any draft assessment proposing variation prejudicial to the taxpayer be examined and the taxpayer be given an opportunity to show cause before finalisation; failure to communicate such draft and to afford show cause opportunity is a breach of the mandatory procedure. Because the Revenue conceded no draft was communicated and no opportunity was given, the final assessment under section 143(3) and consequent demand notice were quashed for non compliance with the faceless assessment requirements, and the petition disposed of with no order as to costs.
Faceless assessment procedure requires that any draft assessment proposing variation prejudicial to the taxpayer be examined and the taxpayer be given an opportunity to show cause before finalisation; failure to communicate such draft and to afford show cause opportunity is a breach of the mandatory procedure. Because the Revenue conceded no draft was communicated and no opportunity was given, the final assessment under section 143(3) and consequent demand notice were quashed for non compliance with the faceless assessment requirements, and the petition disposed of with no order as to costs.
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