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 assessment order violated principles of natural justice as petitioner was not provided further opportunity after show cause notice nine months prior. Petitioner's reply did not address show cause notice. Tax demand confirmed without hearing petitioner. Order set aside, matter remanded for reconsideration on condition petitioner remits 10% of disputed tax demand within two weeks and submits reply to show cause notice. Petition disposed of.
Impugned assessment order violated principles of natural justice as petitioner was not provided further opportunity after show cause notice nine months prior. Petitioner's reply did not address show cause notice. Tax demand confirmed without hearing petitioner. Order set aside, matter remanded for reconsideration on condition petitioner remits 10% of disputed tax demand within two weeks and submits reply to show cause notice. Petition disposed of.
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