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 High Court found that the authorities had violated the principles of natural justice by cancelling the petitioner's registration without providing an opportunity for a hearing or assigning reasons. Despite a previous judgment directing the authorities to issue show cause notices and orders with necessary details in physical form, they issued cryptic notices and orders for cancellation without following the guidelines. The court remanded the matter back to the Assessing Officer at the show cause notice stage, with the petitioner's registration remaining suspended until the show cause notice is decided as per the directions. The petition was disposed of accordingly.
The High Court found that the authorities had violated the principles of natural justice by cancelling the petitioner's registration without providing an opportunity for a hearing or assigning reasons. Despite a previous judgment directing the authorities to issue show cause notices and orders with necessary details in physical form, they issued cryptic notices and orders for cancellation without following the guidelines. The court remanded the matter back to the Assessing Officer at the show cause notice stage, with the petitioner's registration remaining suspended until the show cause notice is decided as per the directions. The petition was disposed of accordingly.
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