Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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