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...
Violation of principles of natural justice - Difference in the turnover as reported in GSTR-3B and as per TDS Return GSTR 2A - Suppression of facts (turnover) or not - for unexplained reasons and circumstances, without any prior intimation or knowledge, the matter was preponed and without affording any opportunity of hearing, decide, holding the view of the revenue. The order does entail civil and pecuniary consequences, causing prejudice to the petitioner. - Matter restored back - HC
Violation of principles of natural justice - Difference in the turnover as reported in GSTR-3B and as per TDS Return GSTR 2A - Suppression of facts (turnover) or not - for unexplained reasons and circumstances, without any prior intimation or knowledge, the matter was preponed and without affording any opportunity of hearing, decide, holding the view of the revenue. The order does entail civil and pecuniary consequences, causing prejudice to the petitioner. - Matter restored back - HC
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