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 service of notices via email address listed on MCA website was valid and compliant with procedural rules. The petitioner received and responded to the scrutiny notice, thereby acknowledging awareness of assessment proceedings. Section 292BB was applicable as the petitioner participated in the inquiry and cannot subsequently challenge notice service. The court found no violation of natural justice principles, rejecting the petitioner's contention of improper notice service. The assessment order was upheld, with the court emphasizing that the petitioner's partial response and subsequent non-compliance undermined its procedural objections.
HC held that the service of notices via email address listed on MCA website was valid and compliant with procedural rules. The petitioner received and responded to the scrutiny notice, thereby acknowledging awareness of assessment proceedings. Section 292BB was applicable as the petitioner participated in the inquiry and cannot subsequently challenge notice service. The court found no violation of natural justice principles, rejecting the petitioner's contention of improper notice service. The assessment order was upheld, with the court emphasizing that the petitioner's partial response and subsequent non-compliance undermined its procedural objections.
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