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...
HC dismissed the writ petition as premature, finding the petitioner's challenge to the departmental show-cause notice unsuited to judicial adjudication absent an administrative reply and supporting documentary evidence. The court held that factual and taxability issues concerning the overseas construction contract and place-of-supply determinations are for the Assessing Officer to examine after receipt of a detailed response; accordingly the petitioner was granted liberty to file a comprehensive reply with all supporting documents in relation to the impugned show-cause notice dated 22.07.2024. The petition is dismissed, with the petitioner directed to submit its reply within 30 days of receipt of the order.
HC dismissed the writ petition as premature, finding the petitioner's challenge to the departmental show-cause notice unsuited to judicial adjudication absent an administrative reply and supporting documentary evidence. The court held that factual and taxability issues concerning the overseas construction contract and place-of-supply determinations are for the Assessing Officer to examine after receipt of a detailed response; accordingly the petitioner was granted liberty to file a comprehensive reply with all supporting documents in relation to the impugned show-cause notice dated 22.07.2024. The petition is dismissed, with the petitioner directed to submit its reply within 30 days of receipt of the order.
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