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 remanded the matter concerning SCN No. 09/2023 due to procedural irregularities in notice service. The court noted that prior to 16th January 2024, show cause notices were uploaded in 'Additional Notices Tab', potentially preventing proper access. Considering the petitioner did not receive adequate opportunity to be heard, the HC directed the adjudicating authority to provide fresh notice. The petitioner was granted time until 15th July 2025 to file reply, with a mandatory personal hearing to be scheduled after submission. The original impugned order was set aside, and the petition was disposed of accordingly.
HC remanded the matter concerning SCN No. 09/2023 due to procedural irregularities in notice service. The court noted that prior to 16th January 2024, show cause notices were uploaded in 'Additional Notices Tab', potentially preventing proper access. Considering the petitioner did not receive adequate opportunity to be heard, the HC directed the adjudicating authority to provide fresh notice. The petitioner was granted time until 15th July 2025 to file reply, with a mandatory personal hearing to be scheduled after submission. The original impugned order was set aside, and the petition was disposed of accordingly.
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