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 Show cause notice - The case pertains to a dealer of woven fabrics and readymade garments challenging a tax demand order due to allegedly insufficient opportunity to contest. Despite delay in response to a show cause notice, subsequent communication and evidence submission by the petitioner suggest efforts to refute discrepancies and comply with requirements. The Government maintains adherence to procedural fairness but acknowledges the petitioner's subsequent explanations for discrepancies. The High Court intervenes, quashing the order subject to conditions ensuring procedural fairness and opportunity for the petitioner to address the tax demand.
Validity Of Show cause notice - The case pertains to a dealer of woven fabrics and readymade garments challenging a tax demand order due to allegedly insufficient opportunity to contest. Despite delay in response to a show cause notice, subsequent communication and evidence submission by the petitioner suggest efforts to refute discrepancies and comply with requirements. The Government maintains adherence to procedural fairness but acknowledges the petitioner's subsequent explanations for discrepancies. The High Court intervenes, quashing the order subject to conditions ensuring procedural fairness and opportunity for the petitioner to address the tax demand.
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