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 disposed of the writ petition by quashing the impugned order, acknowledging the petitioner's failure to respond to the notice in DRC 01. The Court, following its prior approach in similar cases, granted relief on terms rather than outright dismissal. The petitioner was directed to deposit 25% of the disputed tax in cash from the Electronic Cash Register within thirty days from receipt of the order. This conditional quashing balances the petitioner's non-compliance with procedural requirements while providing an opportunity to regularize the disputed tax liability.
The HC disposed of the writ petition by quashing the impugned order, acknowledging the petitioner's failure to respond to the notice in DRC 01. The Court, following its prior approach in similar cases, granted relief on terms rather than outright dismissal. The petitioner was directed to deposit 25% of the disputed tax in cash from the Electronic Cash Register within thirty days from receipt of the order. This conditional quashing balances the petitioner's non-compliance with procedural requirements while providing an opportunity to regularize the disputed tax liability.
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