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 quashed the impugned suspension insofar as it was effected without due investigation into alleged unauthorized changes based on forged documents, finding a violation of principles of natural justice. The Court directed the Joint Commissioner, State Taxes, to afford fresh opportunities to the parties to file responses and to be heard, and to pass an appropriate order after hearing, preferably within four months of receipt of a copy of the order. The HC noted that an earlier interim stay enabled the petitioner to file updated returns and responses, and ordered proceedings to be conducted with affording of statutory fairness before any final tax-administrative action.
The HC allowed the petition and quashed the impugned suspension insofar as it was effected without due investigation into alleged unauthorized changes based on forged documents, finding a violation of principles of natural justice. The Court directed the Joint Commissioner, State Taxes, to afford fresh opportunities to the parties to file responses and to be heard, and to pass an appropriate order after hearing, preferably within four months of receipt of a copy of the order. The HC noted that an earlier interim stay enabled the petitioner to file updated returns and responses, and ordered proceedings to be conducted with affording of statutory fairness before any final tax-administrative action.
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