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...
Court found violation of principles of natural justice as petitioner did not receive notices for proceedings leading to impugned orders. Though e-mail service cannot be ruled out, cancellation of registration could have resulted in petitioner not checking that e-mail ID. Court treated present proceedings as notice, granted three weeks to file response, and remanded matter to adjudicating authority for fresh adjudication after giving proper opportunity to petitioner. Impugned order set aside.
Court found violation of principles of natural justice as petitioner did not receive notices for proceedings leading to impugned orders. Though e-mail service cannot be ruled out, cancellation of registration could have resulted in petitioner not checking that e-mail ID. Court treated present proceedings as notice, granted three weeks to file response, and remanded matter to adjudicating authority for fresh adjudication after giving proper opportunity to petitioner. Impugned order set aside.
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