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 impugned order was passed ex parte without providing notice to the petitioner for the subsequent hearing date, violating principles of natural justice. Relying on a coordinate bench judgment in M/s Shubham Steel Traders Vs. State of U.P. and Another, where it was held that by not passing the order on the scheduled date and not communicating the next date, the assessing authority forced an ex-parte order, the court quashed the impugned order dated March 1, 2024, and directed the authority to grant an opportunity of personal hearing to the petitioner and pass a reasoned order in accordance with law. The petition was disposed of.
The impugned order was passed ex parte without providing notice to the petitioner for the subsequent hearing date, violating principles of natural justice. Relying on a coordinate bench judgment in M/s Shubham Steel Traders Vs. State of U.P. and Another, where it was held that by not passing the order on the scheduled date and not communicating the next date, the assessing authority forced an ex-parte order, the court quashed the impugned order dated March 1, 2024, and directed the authority to grant an opportunity of personal hearing to the petitioner and pass a reasoned order in accordance with law. The petition was disposed of.
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