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...
Conduct of Reassessment Proceedings - Principles of Natural Justice - The High court found that the reassessment proceedings were conducted in great haste, violating the principles of natural justice. The Additional Commissioner granted permission to the Assessing Officer on 18.3.2023, and the notice was issued on 22.3.2023, served on the petitioner on 24.3.2023, with the reassessment order passed on 28.3.2023. The court noted that the petitioner was not given a reasonable opportunity to respond, as only two days were provided to respond to the reassessment notice. The court held that such a procedure undermined the trust in the rule of law and was unacceptable.
Conduct of Reassessment Proceedings - Principles of Natural Justice - The High court found that the reassessment proceedings were conducted in great haste, violating the principles of natural justice. The Additional Commissioner granted permission to the Assessing Officer on 18.3.2023, and the notice was issued on 22.3.2023, served on the petitioner on 24.3.2023, with the reassessment order passed on 28.3.2023. The court noted that the petitioner was not given a reasonable opportunity to respond, as only two days were provided to respond to the reassessment notice. The court held that such a procedure undermined the trust in the rule of law and was unacceptable.
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