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...
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HC upheld cancellation of petitioner's registration under Section 29(2)(e) due to fraudulent misrepresentation of business premises. Despite presenting electricity bills and leave/license agreement, petitioner failed to substantiate actual occupancy through proof of license fee payments or utility charges. Petitioner's inaction in responding to show cause notice, non-appearance before appellate authority, and failure to challenge Bureau of Investigation's spot visit findings proved detrimental. Court found proper officer's inference plausible based on available evidence. The registration cancellation order was deemed neither perverse nor unsupported by evidence, leading to dismissal of writ petition challenging the cancellation order.
HC upheld cancellation of petitioner's registration under Section 29(2)(e) due to fraudulent misrepresentation of business premises. Despite presenting electricity bills and leave/license agreement, petitioner failed to substantiate actual occupancy through proof of license fee payments or utility charges. Petitioner's inaction in responding to show cause notice, non-appearance before appellate authority, and failure to challenge Bureau of Investigation's spot visit findings proved detrimental. Court found proper officer's inference plausible based on available evidence. The registration cancellation order was deemed neither perverse nor unsupported by evidence, leading to dismissal of writ petition challenging the cancellation order.
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