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 petitions on maintainability grounds, emphasizing the availability of an alternate and efficacious remedy by way of appeal. The court held that no patent breach of natural justice occurred, as the petitioners were served with show-cause notices and participated in the proceedings without raising the denial of hearing issue earlier. The refusal of adjournment did not amount to prejudice or a violation warranting departure from the rule of exhausting alternate remedies. The petitioners were granted liberty to file appeals against the impugned orders within six weeks, with a directive that the appellate authority consider the appeals on merits without raising limitation objections, given the bona fide prosecution of the petitions within limitation. The petitions were accordingly disposed of.
The HC dismissed the petitions on maintainability grounds, emphasizing the availability of an alternate and efficacious remedy by way of appeal. The court held that no patent breach of natural justice occurred, as the petitioners were served with show-cause notices and participated in the proceedings without raising the denial of hearing issue earlier. The refusal of adjournment did not amount to prejudice or a violation warranting departure from the rule of exhausting alternate remedies. The petitioners were granted liberty to file appeals against the impugned orders within six weeks, with a directive that the appellate authority consider the appeals on merits without raising limitation objections, given the bona fide prosecution of the petitions within limitation. The petitions were accordingly disposed of.
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