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 recalled the order due to fabrication of show cause notice (SCN), involving material fact deletion and retrospective GST registration cancellation. The court directed: (1) final order stands recalled, (2) proprietor must appear in subsequent hearing, (3) registry to list related writ petitions together, and (4) counsel to intimate petitioners in connected cases. The department challenged the original order, revealing multiple instances of potential SCN manipulation, leading to comprehensive judicial review and procedural rectification.
HC recalled the order due to fabrication of show cause notice (SCN), involving material fact deletion and retrospective GST registration cancellation. The court directed: (1) final order stands recalled, (2) proprietor must appear in subsequent hearing, (3) registry to list related writ petitions together, and (4) counsel to intimate petitioners in connected cases. The department challenged the original order, revealing multiple instances of potential SCN manipulation, leading to comprehensive judicial review and procedural rectification.
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