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 set aside the impugned order N/N. 56/2023-Central Tax due to violation of principles of natural justice. SCN uploaded on 'Additional Notices Tab' without actual knowledge of the Petitioner, resulting in ex parte adjudication without personal hearing. Following precedent in similar case, HC remanded matter for fresh consideration, directing department to provide proper notice, conduct personal hearing, and pass reasoned order after considering Petitioner's submissions on merits.
HC set aside the impugned order N/N. 56/2023-Central Tax due to violation of principles of natural justice. SCN uploaded on 'Additional Notices Tab' without actual knowledge of the Petitioner, resulting in ex parte adjudication without personal hearing. Following precedent in similar case, HC remanded matter for fresh consideration, directing department to provide proper notice, conduct personal hearing, and pass reasoned order after considering Petitioner's submissions on merits.
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