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 assessment order - The High court notes that while the petitioner filed a final return after the cancellation of registration, it's likely they wouldn't have regular access to the portal. Additionally, the assessment order shows the petitioner's non-participation in the proceedings, leading to interference with the impugned order. - Matter restored back for fresh adjudication.
Violation of principles of natural justice - Validity of assessment order - The High court notes that while the petitioner filed a final return after the cancellation of registration, it's likely they wouldn't have regular access to the portal. Additionally, the assessment order shows the petitioner's non-participation in the proceedings, leading to interference with the impugned order. - Matter restored back for fresh adjudication.
Note: It is a system-generated summary and is for quick reference only.
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