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 quashed the original tax assessment order and directed the Deputy Commissioner to provide a hearing and issue a reasoned order considering the taxpayer's reply. The court held that the show cause notice remained valid and proceedings could continue beyond three months. The statutory provision under Section 75(3) allows issuance of remand orders within two years from the original order's communication. The challenge to the Section 74(5) notice was deemed without merit, resulting in the petition's dismissal with no substantial legal grounds supporting the taxpayer's contention.
HC quashed the original tax assessment order and directed the Deputy Commissioner to provide a hearing and issue a reasoned order considering the taxpayer's reply. The court held that the show cause notice remained valid and proceedings could continue beyond three months. The statutory provision under Section 75(3) allows issuance of remand orders within two years from the original order's communication. The challenge to the Section 74(5) notice was deemed without merit, resulting in the petition's dismissal with no substantial legal grounds supporting the taxpayer's contention.
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