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...
Impugned show cause notice reproduced provisions of Section 29(2)(e) without specifying alleged fraud, misstatement or suppression of facts by petitioner. Cancellation order passed in violation of principles of natural justice. Instead of setting aside cancellation order, order rejecting revocation application set aside to provide opportunity to respond to allegations. Petition disposed.
Impugned show cause notice reproduced provisions of Section 29(2)(e) without specifying alleged fraud, misstatement or suppression of facts by petitioner. Cancellation order passed in violation of principles of natural justice. Instead of setting aside cancellation order, order rejecting revocation application set aside to provide opportunity to respond to allegations. Petition disposed.
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