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 order passed by the Tribunal (ITAT) - Non issuance or service of notice to the appellant for hearing - Mere dispatch of a notice is not sufficient. To hold that notice came to the knowledge of the petitioner, the notice should also have been received by the person/assessee to whom it was addressed. There are no records to show the notice of intimation was received by the petitioner. - HC
Validity of order passed by the Tribunal (ITAT) - Non issuance or service of notice to the appellant for hearing - Mere dispatch of a notice is not sufficient. To hold that notice came to the knowledge of the petitioner, the notice should also have been received by the person/assessee to whom it was addressed. There are no records to show the notice of intimation was received by the petitioner. - HC
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