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 due to lack of reasonable opportunity to contest tax demand. Petitioner cited ongoing tax audit and father's illness for seeking adjournment, but failed to submit substantive reply from September 2023 to February 2024 despite sufficient time. Considering health records submitted, petitioner granted opportunity to contest demand by remitting 10% of disputed tax within three weeks. Matter remanded for reconsideration after compliance.
Principles of natural justice violated due to lack of reasonable opportunity to contest tax demand. Petitioner cited ongoing tax audit and father's illness for seeking adjournment, but failed to submit substantive reply from September 2023 to February 2024 despite sufficient time. Considering health records submitted, petitioner granted opportunity to contest demand by remitting 10% of disputed tax within three weeks. Matter remanded for reconsideration after compliance.
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