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...
Petition maintainable despite previously filed appeal. Order passed in violation of principles of natural justice by not allowing petitioner to file reply within stipulated time. Original order liable to be set aside. Fact of filing appeal against original order not a ground to refuse relief when order passed in violation of natural justice. Writ petition allowed, original order quashed, matter remanded for fresh adjudication after providing opportunity of hearing to petitioner.
Petition maintainable despite previously filed appeal. Order passed in violation of principles of natural justice by not allowing petitioner to file reply within stipulated time. Original order liable to be set aside. Fact of filing appeal against original order not a ground to refuse relief when order passed in violation of natural justice. Writ petition allowed, original order quashed, matter remanded for fresh adjudication after providing opportunity of hearing to petitioner.
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