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 petition and set aside the assessment order dated 29.01.2025 and its summary, holding the respondent's proceedings vitiated by breach of natural justice and excessive delay. The court found the petitioner reasonably unaware of portal-notices uploaded after approximately 1½ years and held the statutory/administrative timeline for proceedings under section 73 required prompt adjudication; the belated confirmation of the show-cause proceedings and absence of effective communication rendered the assessment voidable. The matter is remitted to the first respondent for fresh consideration in accordance with law; the petition is allowed by way of remand.
The HC allowed the petition and set aside the assessment order dated 29.01.2025 and its summary, holding the respondent's proceedings vitiated by breach of natural justice and excessive delay. The court found the petitioner reasonably unaware of portal-notices uploaded after approximately 1½ years and held the statutory/administrative timeline for proceedings under section 73 required prompt adjudication; the belated confirmation of the show-cause proceedings and absence of effective communication rendered the assessment voidable. The matter is remitted to the first respondent for fresh consideration in accordance with law; the petition is allowed by way of remand.
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