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 - Validity of prosecution proceedings - service of SCN - Case of petitioners is that, prior to launching the criminal prosecution, no show cause notice was given to the petitioners - The offences alleged against the petitioners are statutory violations for non complying certain mandatory provisions. This Court can gather from the records summoned that the Additional Chief Metropolitan Magistrate had taken cognizance of the cases only after going through the complaint allegations and materials filed in support of the complaint allegations. - These petitions have been filed only to protract the proceedings and deserve to be dismissed - HC
Violation of principles of natural justice - Validity of prosecution proceedings - service of SCN - Case of petitioners is that, prior to launching the criminal prosecution, no show cause notice was given to the petitioners - The offences alleged against the petitioners are statutory violations for non complying certain mandatory provisions. This Court can gather from the records summoned that the Additional Chief Metropolitan Magistrate had taken cognizance of the cases only after going through the complaint allegations and materials filed in support of the complaint allegations. - These petitions have been filed only to protract the proceedings and deserve to be dismissed - HC
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