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...
HC dismissed writ petition challenging assessment order under s.143(3) r.w.s. 144B, finding no clear breach of natural justice principles to warrant bypassing alternate remedies. Show-cause notice adequately informed petitioner about unreliable sales figures and proposed assessment methodology. Final assessment order did not materially deviate from notice parameters. Petitioner's conditional request for video conferencing hearing was not mandatory since AO required no clarifications. Court held statutory appeals must be exhausted first as no patent violation of natural justice was established to justify extraordinary writ jurisdiction.
HC dismissed writ petition challenging assessment order under s.143(3) r.w.s. 144B, finding no clear breach of natural justice principles to warrant bypassing alternate remedies. Show-cause notice adequately informed petitioner about unreliable sales figures and proposed assessment methodology. Final assessment order did not materially deviate from notice parameters. Petitioner's conditional request for video conferencing hearing was not mandatory since AO required no clarifications. Court held statutory appeals must be exhausted first as no patent violation of natural justice was established to justify extraordinary writ jurisdiction.
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