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 proceedings challenged for exceeding scope of show cause notice, non-consideration of submissions during investigation and payments made, gross non-application of mind to material facts, and violation of natural justice principles. Impugned order set aside, petitioner directed to deposit 25% of disputed tax within two weeks, tax already paid adjusted towards deposit. Impugned assessment order treated as show cause notice, petitioner to submit objections with supporting documents within four weeks. Petition disposed of.
Impugned proceedings challenged for exceeding scope of show cause notice, non-consideration of submissions during investigation and payments made, gross non-application of mind to material facts, and violation of natural justice principles. Impugned order set aside, petitioner directed to deposit 25% of disputed tax within two weeks, tax already paid adjusted towards deposit. Impugned assessment order treated as show cause notice, petitioner to submit objections with supporting documents within four weeks. Petition disposed of.
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