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...
Service of SCN - SCN not sent at proper address - The department was fully aware that the appellant is not residing and not available in the address - After the Show Cause Notice was returned, the department paste and affix the Show Cause Notice at the same address - The Show Cause Notice was not issued to the appellant and also that the order has been passed exparte. - Clear violation of principles of natural justice is established - the demand cannot sustain and requires to be set aside - AT
Service of SCN - SCN not sent at proper address - The department was fully aware that the appellant is not residing and not available in the address - After the Show Cause Notice was returned, the department paste and affix the Show Cause Notice at the same address - The Show Cause Notice was not issued to the appellant and also that the order has been passed exparte. - Clear violation of principles of natural justice is established - the demand cannot sustain and requires to be set aside - AT
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