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 ex parte cancellation order dated 21.02.2025, holding that the petitioner was not afforded principles of natural justice as no personal service of the show cause notice was established. The Court noted the petitioner had ceased business prior to the notice period and thus had no opportunity to respond. Relying on precedents, the HC remanded the matter to the assessing authority, directing that the petitioner be given a fair opportunity to submit a response within three weeks and be heard before a fresh order is passed. The petition was allowed by way of remand, ensuring compliance with procedural fairness.
The HC set aside the ex parte cancellation order dated 21.02.2025, holding that the petitioner was not afforded principles of natural justice as no personal service of the show cause notice was established. The Court noted the petitioner had ceased business prior to the notice period and thus had no opportunity to respond. Relying on precedents, the HC remanded the matter to the assessing authority, directing that the petitioner be given a fair opportunity to submit a response within three weeks and be heard before a fresh order is passed. The petition was allowed by way of remand, ensuring compliance with procedural fairness.
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