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 HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed to justify the delay satisfactorily. The SC order cited does not mandate excusing gross, unjustifiable, and inordinate delays in adjudicating show cause notices without reasonable explanation. Consequently, the HC restrained the respondents from further proceedings based on the impugned show cause notice.
The HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed to justify the delay satisfactorily. The SC order cited does not mandate excusing gross, unjustifiable, and inordinate delays in adjudicating show cause notices without reasonable explanation. Consequently, the HC restrained the respondents from further proceedings based on the impugned show cause notice.
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