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...
The petition was declined on grounds of maintainability due to availability of an alternate efficacious remedy of appeal against the impugned order. The contention regarding failure of principles of natural justice due to lack of opportunity of hearing was rejected, as intimations were sent to the petitioner's registered address, and the petitioner failed to notify the change of address. It was held that it was a case of "no adequate notice" rather than "no notice," and in such cases, the party must establish prejudice. Consequently, the petitioner was relegated to avail the alternate remedy of appeal, and the petition was disposed of.
The petition was declined on grounds of maintainability due to availability of an alternate efficacious remedy of appeal against the impugned order. The contention regarding failure of principles of natural justice due to lack of opportunity of hearing was rejected, as intimations were sent to the petitioner's registered address, and the petitioner failed to notify the change of address. It was held that it was a case of "no adequate notice" rather than "no notice," and in such cases, the party must establish prejudice. Consequently, the petitioner was relegated to avail the alternate remedy of appeal, and the petition was disposed of.
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