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 SCN was improperly served by uploading it to the Additional notices tab, violating principles of natural justice. Following precedent, the SCN was set aside. The Adjudicating Authority must reissue the SCN and pass a fresh adjudication order, which remains subject to potential Supreme Court review of the underlying notification. The demand order dated 27th December 2023 was consequently nullified due to procedural irregularities in SCN service, effectively rendering the original tax demand invalid.
HC held that the SCN was improperly served by uploading it to the Additional notices tab, violating principles of natural justice. Following precedent, the SCN was set aside. The Adjudicating Authority must reissue the SCN and pass a fresh adjudication order, which remains subject to potential Supreme Court review of the underlying notification. The demand order dated 27th December 2023 was consequently nullified due to procedural irregularities in SCN service, effectively rendering the original tax demand invalid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
