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 allowed the petition challenging Rule 86A blocking of Electronic Credit Ledger (ECL), finding the order invalid due to lack of pre-decisional hearing and absence of independent, cogent reasons. The court held that reliance on borrowed satisfaction from enforcement reports without providing specific grounds constitutes an arbitrary action. Respondents were directed to immediately unblock the petitioner's ECL, enabling the petitioner to file returns, thus upholding principles of natural justice and procedural fairness in tax administration.
HC allowed the petition challenging Rule 86A blocking of Electronic Credit Ledger (ECL), finding the order invalid due to lack of pre-decisional hearing and absence of independent, cogent reasons. The court held that reliance on borrowed satisfaction from enforcement reports without providing specific grounds constitutes an arbitrary action. Respondents were directed to immediately unblock the petitioner's ECL, enabling the petitioner to file returns, thus upholding principles of natural justice and procedural fairness in tax administration.
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