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...
Challenge to the cancellation of registration and rejection of an application for revocation of cancellation. The key points are: The show cause notice (SCN) did not identify the issuing authority, violating principles of natural justice as the petitioner could not adequately respond. The SCN lacked details about the alleged fraud, misstatement, or suppression. The order canceling registration and rejecting the revocation application was vague and non-speaking, without providing reasons. Consequently, the High Court set aside the impugned order dated 2nd January 2024 and disposed of the writ petition.
Challenge to the cancellation of registration and rejection of an application for revocation of cancellation. The key points are: The show cause notice (SCN) did not identify the issuing authority, violating principles of natural justice as the petitioner could not adequately respond. The SCN lacked details about the alleged fraud, misstatement, or suppression. The order canceling registration and rejecting the revocation application was vague and non-speaking, without providing reasons. Consequently, the High Court set aside the impugned order dated 2nd January 2024 and disposed of the writ petition.
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