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...
Notices issued to a deceased person and subsequent assessment orders passed based on such notices are void ab initio, violating principles of natural justice. The High Court held that issuing notices and passing orders against a deceased assessee, without knowledge of their demise, renders the proceedings ex parte and suffers from violation of natural justice. Consequently, the impugned orders and consequential recovery proceedings were set aside, and the matter was remitted for fresh consideration by the authority.
Notices issued to a deceased person and subsequent assessment orders passed based on such notices are void ab initio, violating principles of natural justice. The High Court held that issuing notices and passing orders against a deceased assessee, without knowledge of their demise, renders the proceedings ex parte and suffers from violation of natural justice. Consequently, the impugned orders and consequential recovery proceedings were set aside, and the matter was remitted for fresh consideration by the authority.
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