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 dismissed the petition challenging the respondents' jurisdiction and penalty imposition, affirming that due process was followed. The consignment was intercepted from the driver, who produced relevant documents; notices were issued accordingly, and physical verification occurred in his presence. The petitioner, as the sole authorized signatory, was granted a reasonable opportunity to be heard, both through written submissions and legal representation. The adjudicating and appellate authorities thoroughly considered the petitioner's contentions before confirming the penalty. The Court held that mens rea is not required to establish liability for willful tax evasion under the relevant statute. Precedents cited by the petitioner were distinguished or deemed inapplicable. The Court found the petition meritless and set aside the impugned order, thereby upholding the penalty and dismissing the writ petition.
The HC dismissed the petition challenging the respondents' jurisdiction and penalty imposition, affirming that due process was followed. The consignment was intercepted from the driver, who produced relevant documents; notices were issued accordingly, and physical verification occurred in his presence. The petitioner, as the sole authorized signatory, was granted a reasonable opportunity to be heard, both through written submissions and legal representation. The adjudicating and appellate authorities thoroughly considered the petitioner's contentions before confirming the penalty. The Court held that mens rea is not required to establish liability for willful tax evasion under the relevant statute. Precedents cited by the petitioner were distinguished or deemed inapplicable. The Court found the petition meritless and set aside the impugned order, thereby upholding the penalty and dismissing the writ petition.
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