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...
Order cancelling petitioner's registration violated principles of natural justice as it was passed mechanically without application of mind and without assigning reasons. Appeal against cancellation dismissed on ground of delay. Reasons are essential for judicial and administrative orders. Doctrine of merger inapplicable due to circumstances. Referring to precedent, order without reasons fails Article 14 test of reasonableness. Impugned cancellation order quashed for lack of reasons, allowing the petition.
Order cancelling petitioner's registration violated principles of natural justice as it was passed mechanically without application of mind and without assigning reasons. Appeal against cancellation dismissed on ground of delay. Reasons are essential for judicial and administrative orders. Doctrine of merger inapplicable due to circumstances. Referring to precedent, order without reasons fails Article 14 test of reasonableness. Impugned cancellation order quashed for lack of reasons, allowing the petition.
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