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...
Suspension of operations of handling the cargo of third parties - The High Court observes that the absence of a show cause notice and an opportunity for a hearing violates fundamental principles of natural justice, particularly given the significant civil consequences of the order. Additionally, the Court takes into account the potential adverse impact on third parties associated with the petitioners. Consequently, it orders the remand of proceedings to the Commissioner for a fresh order, emphasizing the necessity of adherence to procedural fairness.
Suspension of operations of handling the cargo of third parties - The High Court observes that the absence of a show cause notice and an opportunity for a hearing violates fundamental principles of natural justice, particularly given the significant civil consequences of the order. Additionally, the Court takes into account the potential adverse impact on third parties associated with the petitioners. Consequently, it orders the remand of proceedings to the Commissioner for a fresh order, emphasizing the necessity of adherence to procedural fairness.
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