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 set aside the cancellation order dated 6th August 2024 and the subsequent appellate order dated 21st March 2025, restoring the petitioner's registration. The court found that while registration was cancelled for non-filing of returns, there was no evidence of dubious tax evasion practices. Emphasizing that suspension would be counterproductive to revenue interests as it prevents business operations and tax recovery, the court adopted a pragmatic approach. The restoration was granted conditionally, requiring the petitioner to file all outstanding returns for the default period and pay requisite taxes, interest, fines, and penalties. The court noted that respondents cannot determine final liability without filed returns, making restoration essential for proper tax administration.
The HC set aside the cancellation order dated 6th August 2024 and the subsequent appellate order dated 21st March 2025, restoring the petitioner's registration. The court found that while registration was cancelled for non-filing of returns, there was no evidence of dubious tax evasion practices. Emphasizing that suspension would be counterproductive to revenue interests as it prevents business operations and tax recovery, the court adopted a pragmatic approach. The restoration was granted conditionally, requiring the petitioner to file all outstanding returns for the default period and pay requisite taxes, interest, fines, and penalties. The court noted that respondents cannot determine final liability without filed returns, making restoration essential for proper tax administration.
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