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...
Writ petition challenging order of assessment and DRC-07 notice issued without opportunity to petitioner, violating principles of natural justice. Held that no reasons assigned for rejecting rectification application u/s 161 of TNGST Act, except stating no satisfactory reasons attached. Petitioner pointed out error in return seeking revised assessment order. Impugned order rejecting rectification set aside, matter remitted to pass fresh order considering reasons, else give detailed reasons for rejection. Further DRC-07 proceedings kept in abeyance. Writ petition disposed of.
Writ petition challenging order of assessment and DRC-07 notice issued without opportunity to petitioner, violating principles of natural justice. Held that no reasons assigned for rejecting rectification application u/s 161 of TNGST Act, except stating no satisfactory reasons attached. Petitioner pointed out error in return seeking revised assessment order. Impugned order rejecting rectification set aside, matter remitted to pass fresh order considering reasons, else give detailed reasons for rejection. Further DRC-07 proceedings kept in abeyance. Writ petition disposed of.
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