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 dismissed the petition challenging tax proceedings, finding no violation of natural justice. The petitioner received hearing notice but failed to appear, and the court clarified that statutory provisions do not mandate exactly three hearings. The court directed the petitioner to file an appeal under Section 107 of CGST Act to the Appellate Authority, effectively upholding the department's procedural actions and rejecting claims of improper notice or hearing.
HC dismissed the petition challenging tax proceedings, finding no violation of natural justice. The petitioner received hearing notice but failed to appear, and the court clarified that statutory provisions do not mandate exactly three hearings. The court directed the petitioner to file an appeal under Section 107 of CGST Act to the Appellate Authority, effectively upholding the department's procedural actions and rejecting claims of improper notice or hearing.
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