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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Electronic transmission of summons and relied-upon documents satisfied Rule 13(3)(iii) read with Rule 13(11) and Section 13 of the IT Act, and email delivery of PDF RUDs was held valid; recording of reasons to believe under Section 8(1) PMLA was examined and upheld as based on perusal of RUDs and investigation material; the Adjudicating Authority must determine whether specific documents qualify as relied upon documents and, if so, order their supply and permit a two week supplementary reply, with aggrieved parties able to seek remedies under Section 26 PMLA.
Electronic transmission of summons and relied-upon documents satisfied Rule 13(3)(iii) read with Rule 13(11) and Section 13 of the IT Act, and email delivery of PDF RUDs was held valid; recording of reasons to believe under Section 8(1) PMLA was examined and upheld as based on perusal of RUDs and investigation material; the Adjudicating Authority must determine whether specific documents qualify as relied upon documents and, if so, order their supply and permit a two week supplementary reply, with aggrieved parties able to seek remedies under Section 26 PMLA.
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