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 in tax adjudication process under U.P. GST Act, 2017. No opportunity for personal hearing provided to petitioner despite request in reply to show cause notice. Writ petition allowed, impugned order dated 17.08.2022 set aside. Assessing Officer directed to fix date, time, and place for personal hearing within two weeks of receiving certified copy of order, as petitioner had already submitted reply to show cause notice.
Principles of natural justice violated in tax adjudication process under U.P. GST Act, 2017. No opportunity for personal hearing provided to petitioner despite request in reply to show cause notice. Writ petition allowed, impugned order dated 17.08.2022 set aside. Assessing Officer directed to fix date, time, and place for personal hearing within two weeks of receiving certified copy of order, as petitioner had already submitted reply to show cause notice.
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