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...
Principles of Natural Justice - There has been lapse on the part of the petitioner which now is sought to be explained as a mistake and error committed by the petitioner. Once the petitioner itself admits that there were lapses and error on its part, it cannot be termed that there has been gross miscarriage of justice by the authorities requiring interference by the High Court at the very first instance. - HC
Principles of Natural Justice - There has been lapse on the part of the petitioner which now is sought to be explained as a mistake and error committed by the petitioner. Once the petitioner itself admits that there were lapses and error on its part, it cannot be termed that there has been gross miscarriage of justice by the authorities requiring interference by the High Court at the very first instance. - HC
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