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 adjudicated a tax dispute involving notification challenges, granting the petitioner an opportunity to file a reply to the Show Cause Notice (SCN) within one month. The court noted that the SCN was uploaded on an additional tab without the petitioner's direct knowledge. The proceedings were deemed subject to the Supreme Court's pending decision on the validity of the impugned notifications. The court permitted the petitioner to pursue appellate remedies while reserving final determination pending the Supreme Court's verdict. The petition was disposed of with directions for the adjudicating authority to hear the petitioner's arguments on merits without passing default orders.
HC adjudicated a tax dispute involving notification challenges, granting the petitioner an opportunity to file a reply to the Show Cause Notice (SCN) within one month. The court noted that the SCN was uploaded on an additional tab without the petitioner's direct knowledge. The proceedings were deemed subject to the Supreme Court's pending decision on the validity of the impugned notifications. The court permitted the petitioner to pursue appellate remedies while reserving final determination pending the Supreme Court's verdict. The petition was disposed of with directions for the adjudicating authority to hear the petitioner's arguments on merits without passing default orders.
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