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...
The HC quashed the impugned order for violating principles of natural justice, as the petitioner's explanation during personal hearing was not discussed. It remanded the case to the respondent to pass a fresh order on merits after the petitioner deposits 10% of disputed tax and files a consolidated reply within 30 days, treating the quashed order as an addendum to the earlier show cause notice.
The HC quashed the impugned order for violating principles of natural justice, as the petitioner's explanation during personal hearing was not discussed. It remanded the case to the respondent to pass a fresh order on merits after the petitioner deposits 10% of disputed tax and files a consolidated reply within 30 days, treating the quashed order as an addendum to the earlier show cause notice.
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