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...
The HC quashed the impugned order for violating principles of natural justice, as the authority failed to consider the petitioner's defense reply to the show cause notice regarding recovery of service tax with interest and penalty. The petitioner had claimed exemption under Mega exemption Notification 25/2012, but this defense was apparently "forgotten" by the adjudicating authority. The matter was remanded to the competent authority with directions to consider the petitioner's reply, provide an opportunity for hearing, and pass a fresh order in accordance with law. The application was allowed.
The HC quashed the impugned order for violating principles of natural justice, as the authority failed to consider the petitioner's defense reply to the show cause notice regarding recovery of service tax with interest and penalty. The petitioner had claimed exemption under Mega exemption Notification 25/2012, but this defense was apparently "forgotten" by the adjudicating authority. The matter was remanded to the competent authority with directions to consider the petitioner's reply, provide an opportunity for hearing, and pass a fresh order in accordance with law. The application was allowed.
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