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...
Principles of natural justice violated as petitioner was not provided reasonable opportunity to contest tax demand due to unawareness of proceedings entrusted to accountant who left abruptly, leading to mismatch between GSTR 3B and auto-populated GSTR 2A. Impugned order set aside on condition of remitting 10% of disputed tax demand within two weeks and permitting petitioner to reply to show cause notice. Petition disposed.
Principles of natural justice violated as petitioner was not provided reasonable opportunity to contest tax demand due to unawareness of proceedings entrusted to accountant who left abruptly, leading to mismatch between GSTR 3B and auto-populated GSTR 2A. Impugned order set aside on condition of remitting 10% of disputed tax demand within two weeks and permitting petitioner to reply to show cause notice. Petition disposed.
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