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 examined a challenge to an adjudication order allegedly issued without providing hearing opportunity. Despite claims of natural justice violation, the court found extensive documentation requiring detailed factual analysis. Determining this was not an exceptional case warranting bypass of statutory appeal mechanisms, HC dismissed the appeal. However, court granted appellant 30 days from judgment receipt to file statutory appeal, directing appellate authority to accept it without limitation period restrictions. Court emphasized need for thorough factual adjudication through proper appellate channels rather than direct judicial intervention.
HC examined a challenge to an adjudication order allegedly issued without providing hearing opportunity. Despite claims of natural justice violation, the court found extensive documentation requiring detailed factual analysis. Determining this was not an exceptional case warranting bypass of statutory appeal mechanisms, HC dismissed the appeal. However, court granted appellant 30 days from judgment receipt to file statutory appeal, directing appellate authority to accept it without limitation period restrictions. Court emphasized need for thorough factual adjudication through proper appellate channels rather than direct judicial intervention.
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