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...
Writ petition challenging show cause notice (SCN) and adjudication order attaching petitioner's bank account. SCN not uploaded in "view notices and orders" section of portal, violating principles of natural justice. Court held petitioner entitled to 30 days to respond to SCN u/s 73(8) of Act. Though SCN uploaded in "view additional notices and orders" section, confusion in identifying notices in pre-redesigned portal dashboard. Petitioner permitted to approach appellate authority. Attachment order quashed for lack of opportunity to respond. Petition disposed of.
Writ petition challenging show cause notice (SCN) and adjudication order attaching petitioner's bank account. SCN not uploaded in "view notices and orders" section of portal, violating principles of natural justice. Court held petitioner entitled to 30 days to respond to SCN u/s 73(8) of Act. Though SCN uploaded in "view additional notices and orders" section, confusion in identifying notices in pre-redesigned portal dashboard. Petitioner permitted to approach appellate authority. Attachment order quashed for lack of opportunity to respond. Petition disposed of.
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