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 impugned order imposing the penalty, noting that although the petitioner was represented at the personal hearing and lost the right of appeal due to delay, the petitioner must be afforded one final opportunity to present their case before the authority. The petitioner is directed to communicate a certified copy of the HC order to the authority by 30 December 2024; failure to do so will result in automatic restoration of the original order. Upon receipt, the authority shall schedule a hearing to allow the petitioner a last chance to be heard and thereafter pass a fresh adjudicatory order. The petition is disposed of accordingly.
The HC set aside the impugned order imposing the penalty, noting that although the petitioner was represented at the personal hearing and lost the right of appeal due to delay, the petitioner must be afforded one final opportunity to present their case before the authority. The petitioner is directed to communicate a certified copy of the HC order to the authority by 30 December 2024; failure to do so will result in automatic restoration of the original order. Upon receipt, the authority shall schedule a hearing to allow the petitioner a last chance to be heard and thereafter pass a fresh adjudicatory order. The petition is disposed of accordingly.
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