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 held that the respondent authority's issuance of a show cause notice (SCN) to a non-existent company post-amalgamation was procedurally flawed. Despite initial claims of unawareness, the respondent's counsel acknowledged knowledge of the amalgamation. The court set aside the impugned order and granted liberty to the respondents to initiate fresh proceedings against the resultant entity in compliance with legal protocols, effectively nullifying the previous SCN and providing an opportunity for procedural rectification.
HC held that the respondent authority's issuance of a show cause notice (SCN) to a non-existent company post-amalgamation was procedurally flawed. Despite initial claims of unawareness, the respondent's counsel acknowledged knowledge of the amalgamation. The court set aside the impugned order and granted liberty to the respondents to initiate fresh proceedings against the resultant entity in compliance with legal protocols, effectively nullifying the previous SCN and providing an opportunity for procedural rectification.
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