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...
Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned order, found taxpayer's reply and documents were considered for most defects except two. For those two defects, court set aside impugned order subject to taxpayer remitting 20% of disputed tax demand and re-submitting relevant documents within 15 days. Tax authority directed to provide reasonable opportunity including personal hearing to taxpayer and pass fresh order within 3 months after receiving taxpayer's reply. Petition disposed.
Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned order, found taxpayer's reply and documents were considered for most defects except two. For those two defects, court set aside impugned order subject to taxpayer remitting 20% of disputed tax demand and re-submitting relevant documents within 15 days. Tax authority directed to provide reasonable opportunity including personal hearing to taxpayer and pass fresh order within 3 months after receiving taxpayer's reply. Petition disposed.
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