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 dismissed the appeal challenging the order issued by the National Faceless Appeal Centre (NFAC) u/s 250 of the Income Tax Act. The court held that the appellant was afforded sufficient opportunity to produce supporting documents, but repeatedly sought adjournments without producing any documents, indicating a delay tactic. The notices issued u/s 250 satisfied the statutory requirements, explicitly conveying the purpose of the hearing. The appellant's contention of violation of natural justice principles was rejected, as a person who fails to avail the opportunity to make submissions and produce documents cannot complain about such violation. However, the High Court modified the single judge's direction requiring the appellant to remit 20% of the disputed tax as a pre-condition for filing a stay petition before the Appellate Tribunal.
The High Court dismissed the appeal challenging the order issued by the National Faceless Appeal Centre (NFAC) u/s 250 of the Income Tax Act. The court held that the appellant was afforded sufficient opportunity to produce supporting documents, but repeatedly sought adjournments without producing any documents, indicating a delay tactic. The notices issued u/s 250 satisfied the statutory requirements, explicitly conveying the purpose of the hearing. The appellant's contention of violation of natural justice principles was rejected, as a person who fails to avail the opportunity to make submissions and produce documents cannot complain about such violation. However, the High Court modified the single judge's direction requiring the appellant to remit 20% of the disputed tax as a pre-condition for filing a stay petition before the Appellate Tribunal.
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