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 allowed the writ petitions by quashing the impugned assessment orders and remitting the matters to the respondents for fresh adjudication on merits. The court noted the petitioners' failure to respond to preceding show-cause notices and considered the applicability of notifications issued under Section 168A. In view of a recent decision of the Principal Bench invalidating the impugned Section 168A notification with consequential directions, the HC set aside the assessments without deciding substantive tax liability and directed the respondents to proceed afresh, observing that consequential statutory and procedural safeguards be afforded on reconsideration. The writ petitions are disposed of accordingly.
The HC allowed the writ petitions by quashing the impugned assessment orders and remitting the matters to the respondents for fresh adjudication on merits. The court noted the petitioners' failure to respond to preceding show-cause notices and considered the applicability of notifications issued under Section 168A. In view of a recent decision of the Principal Bench invalidating the impugned Section 168A notification with consequential directions, the HC set aside the assessments without deciding substantive tax liability and directed the respondents to proceed afresh, observing that consequential statutory and procedural safeguards be afforded on reconsideration. The writ petitions are disposed of accordingly.
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