Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Validity of assessment order - assessee requested to summon books of accounts and invoices from the dealers and suppliers - the illegality committed in this behalf is that no order on the request of the petitioner is made and then the very valuable opportunity is denied to prove the case of the petitioner - order passed u/s 25 of KVAT Act is unsustainable as violative of principles of natural justice - remanded for fresh decision
Validity of assessment order - assessee requested to summon books of accounts and invoices from the dealers and suppliers - the illegality committed in this behalf is that no order on the request of the petitioner is made and then the very valuable opportunity is denied to prove the case of the petitioner - order passed u/s 25 of KVAT Act is unsustainable as violative of principles of natural justice - remanded for fresh decision
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