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 High Court quashed the assessment order dated 06.08.2024, holding that the Assessing Authority violated the principles of natural justice by denying an opportunity of personal hearing to the petitioner despite a specific request. Although the show-cause notice indicated 'NA' for personal hearing, the petitioner marked 'Yes' in the reply and sought an opportunity. The Court ruled that any previous opportunity before issuing the show-cause notice was inconsequential. The impending expiry of the limitation period did not justify denying a hearing. The authorities were directed to pass a fresh order after affording an opportunity of hearing to the petitioner.
The High Court quashed the assessment order dated 06.08.2024, holding that the Assessing Authority violated the principles of natural justice by denying an opportunity of personal hearing to the petitioner despite a specific request. Although the show-cause notice indicated 'NA' for personal hearing, the petitioner marked 'Yes' in the reply and sought an opportunity. The Court ruled that any previous opportunity before issuing the show-cause notice was inconsequential. The impending expiry of the limitation period did not justify denying a hearing. The authorities were directed to pass a fresh order after affording an opportunity of hearing to the petitioner.
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