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...
The rectification order was set aside for breach of natural justice because it had been passed without affording the petitioner a hearing and without considering its submissions and documents. The Court treated this procedural illegality as the ative defect and directed de novo consideration by the designated authority. The authority was permitted to issue a fresh show cause notice, grant personal hearing, and pass a reasoned and speaking order, with all rival contentions left open for fresh adjudication.
The rectification order was set aside for breach of natural justice because it had been passed without affording the petitioner a hearing and without considering its submissions and documents. The Court treated this procedural illegality as the ative defect and directed de novo consideration by the designated authority. The authority was permitted to issue a fresh show cause notice, grant personal hearing, and pass a reasoned and speaking order, with all rival contentions left open for fresh adjudication.
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