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...
Issuance of second SCN without adjudicating first SCN - Valuation - the Tribunal found merit in the Appellant's arguments. It noted that the Department had pursued two show-cause notices for the same period, despite a previous adjudication favoring the Appellant and despite legal precedent prohibiting such actions. As a result, the Tribunal set aside the order passed by the Commissioner (Appeals) and allowed the appeal, granting consequential relief to the Appellant.
Issuance of second SCN without adjudicating first SCN - Valuation - the Tribunal found merit in the Appellant's arguments. It noted that the Department had pursued two show-cause notices for the same period, despite a previous adjudication favoring the Appellant and despite legal precedent prohibiting such actions. As a result, the Tribunal set aside the order passed by the Commissioner (Appeals) and allowed the appeal, granting consequential relief to the Appellant.
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