Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
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A refund claim arising from export of services was rejected by a non-speaking order that failed to record any specific finding on entitlement and merely reproduced clauses of the agreement. The High Court held that such bald disposal was contrary to the requirement of a reasoned determination and principles of natural justice, because the authority did not adjudicate the petitioner's submissions or material before it. The impugned appellate order was quashed, and the matter was remanded for de novo consideration by the original authority with an opportunity of hearing, leaving all contentions open.
A refund claim arising from export of services was rejected by a non-speaking order that failed to record any specific finding on entitlement and merely reproduced clauses of the agreement. The High Court held that such bald disposal was contrary to the requirement of a reasoned determination and principles of natural justice, because the authority did not adjudicate the petitioner's submissions or material before it. The impugned appellate order was quashed, and the matter was remanded for de novo consideration by the original authority with an opportunity of hearing, leaving all contentions open.
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