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...
Impugned order quashed due to violation of principles of natural justice as second notice failed to mention time or date for personal hearing. Case remitted to pass fresh orders on merits and in accordance with law within 60 days, treating impugned order as addendum to preceding show cause notice, considering recovery of Rs. 38 lakhs from petitioner's account.
Impugned order quashed due to violation of principles of natural justice as second notice failed to mention time or date for personal hearing. Case remitted to pass fresh orders on merits and in accordance with law within 60 days, treating impugned order as addendum to preceding show cause notice, considering recovery of Rs. 38 lakhs from petitioner's account.
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