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 and fair play were violated when the impugned order was issued without granting the petitioner an opportunity for a hearing. Despite the delay in responding to the show cause notice, the petitioner should be allowed to file a reply and be heard, subject to paying costs of Rs. 50,000/-. The respondent must dispose of the show cause notice expeditiously after considering the reply, within eight weeks of receiving it. The petition is disposed of accordingly.
Principles of natural justice and fair play were violated when the impugned order was issued without granting the petitioner an opportunity for a hearing. Despite the delay in responding to the show cause notice, the petitioner should be allowed to file a reply and be heard, subject to paying costs of Rs. 50,000/-. The respondent must dispose of the show cause notice expeditiously after considering the reply, within eight weeks of receiving it. The petition is disposed of accordingly.
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