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 show cause notice (SCN) issued on 27th September, 2023, was not properly communicated to the petitioner, violating principles of natural justice. Following precedent in a similar case, the court remanded the matter back to the adjudicating authority. The impugned order was set aside, and the petitioner was granted time until 10th July 2025, to file a reply to the SCN. The court directed that hearing notices must be e-mailed to the petitioner and not merely uploaded on the portal, ensuring proper opportunity to be heard.
HC held that the show cause notice (SCN) issued on 27th September, 2023, was not properly communicated to the petitioner, violating principles of natural justice. Following precedent in a similar case, the court remanded the matter back to the adjudicating authority. The impugned order was set aside, and the petitioner was granted time until 10th July 2025, to file a reply to the SCN. The court directed that hearing notices must be e-mailed to the petitioner and not merely uploaded on the portal, ensuring proper opportunity to be heard.
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