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...
Petitioner's registration cancelled for non-filing GST returns for six months without notice - violation of natural justice principles. HC held cancellation order passed on different ground of non-compliance with Rule 21A(2A) without notice to petitioner - grossly violating natural justice. Appellate order not on merits, hence doctrine of merger inapplicable. Cancellation order unsustainable, petition allowed.
Petitioner's registration cancelled for non-filing GST returns for six months without notice - violation of natural justice principles. HC held cancellation order passed on different ground of non-compliance with Rule 21A(2A) without notice to petitioner - grossly violating natural justice. Appellate order not on merits, hence doctrine of merger inapplicable. Cancellation order unsustainable, petition allowed.
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