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 assessment order u/s 74 - The order passed based on a report from the Irrigation and Waterways Directorate, Govt. of West Bengal, regarding the disclosure of turnover of outward taxable supply during a specific tax period. - The High Court noted that the failure to provide the report to the petitioner violated principles of natural justice, as the petitioner was not given the opportunity to respond to the content of the report that formed the basis of the adjudication. - Matter restored back.
Validity of assessment order u/s 74 - The order passed based on a report from the Irrigation and Waterways Directorate, Govt. of West Bengal, regarding the disclosure of turnover of outward taxable supply during a specific tax period. - The High Court noted that the failure to provide the report to the petitioner violated principles of natural justice, as the petitioner was not given the opportunity to respond to the content of the report that formed the basis of the adjudication. - Matter restored back.
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