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...
Cancellation of petitioner's registration due to alleged fraud, willful misstatement, or suppression of facts in obtaining registration. Proper Officer issued show cause notice, but petitioner claimed non-disclosure of basis. Proper Officer clarified and provided documents. Petitioner filed response, but Proper Officer canceled registration on premise of non-reply. Matter remanded to Proper Officer for reconsideration of petitioner's case, taking note of response and affording opportunity of hearing. Petition disposed by way of remand.
Cancellation of petitioner's registration due to alleged fraud, willful misstatement, or suppression of facts in obtaining registration. Proper Officer issued show cause notice, but petitioner claimed non-disclosure of basis. Proper Officer clarified and provided documents. Petitioner filed response, but Proper Officer canceled registration on premise of non-reply. Matter remanded to Proper Officer for reconsideration of petitioner's case, taking note of response and affording opportunity of hearing. Petition disposed by way of remand.
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