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 maintainable despite alternative remedy due to violation of principles of natural justice and lack of jurisdiction. Impugned order set aside by HC for non-application of mind to petitioner's objection and traversing beyond show cause notice in contravention of Section 75(7) of the Act. Failure to consider reply vitiates proceedings under settled law. Petition disposed of.
Writ petition maintainable despite alternative remedy due to violation of principles of natural justice and lack of jurisdiction. Impugned order set aside by HC for non-application of mind to petitioner's objection and traversing beyond show cause notice in contravention of Section 75(7) of the Act. Failure to consider reply vitiates proceedings under settled law. Petition disposed of.
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