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...
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
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