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...
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A, finding violation of natural justice principles. The court held that respondents failed to provide pre-decisional hearing and the impugned order lacked independent reasons to believe, impermissibly relying on borrowed satisfaction from enforcement authority reports. Following precedent in K-9-Enterprises, the court determined mandatory prerequisites under Rule 86A were not fulfilled, rendering the blocking order illegal and arbitrary. The HC directed immediate unblocking of petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition was allowed with the impugned order being quashed entirely.
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A, finding violation of natural justice principles. The court held that respondents failed to provide pre-decisional hearing and the impugned order lacked independent reasons to believe, impermissibly relying on borrowed satisfaction from enforcement authority reports. Following precedent in K-9-Enterprises, the court determined mandatory prerequisites under Rule 86A were not fulfilled, rendering the blocking order illegal and arbitrary. The HC directed immediate unblocking of petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition was allowed with the impugned order being quashed entirely.
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