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 revival notices - original show cause notices were issued to the petitioners between the years 2007 and 2012 - revival of these proceedings after a gross inordinate and unexplained delay is clearly unjustified. Furthermore, non-intimation of the decision to transfer the original show cause notices to the Call Book to the petitioners herein, has resulted into grave prejudice being caused to them because on account of the delay in revival of the notices, the opportunity of contesting the assessment proceedings has been severely impaired. - HC
Validity of revival notices - original show cause notices were issued to the petitioners between the years 2007 and 2012 - revival of these proceedings after a gross inordinate and unexplained delay is clearly unjustified. Furthermore, non-intimation of the decision to transfer the original show cause notices to the Call Book to the petitioners herein, has resulted into grave prejudice being caused to them because on account of the delay in revival of the notices, the opportunity of contesting the assessment proceedings has been severely impaired. - HC
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