Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Rejection of a refund claim without considering the taxpayer's request for a personal hearing and without fixing a hearing date violated the prescribed statutory procedure. The High Court noted that the reply to the show cause notice had expressly sought a virtual hearing, yet the authority proceeded to reject the claim without granting that opportunity. As the Rules required hearing before a refund application could be rejected, the order was held to suffer from procedural breach. The refund rejection was quashed and the matter remitted to the competent authority for fresh consideration in accordance with law.
Rejection of a refund claim without considering the taxpayer's request for a personal hearing and without fixing a hearing date violated the prescribed statutory procedure. The High Court noted that the reply to the show cause notice had expressly sought a virtual hearing, yet the authority proceeded to reject the claim without granting that opportunity. As the Rules required hearing before a refund application could be rejected, the order was held to suffer from procedural breach. The refund rejection was quashed and the matter remitted to the competent authority for fresh consideration in accordance with law.
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