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 set aside the impugned demand order and remanded the matter to the Adjudicating Authority for fresh adjudication, finding a breach of audi alteram partem where the SCN and subsequent notices were uploaded only to the "Additional Notices" tab and the Petitioner was not afforded a real opportunity to be heard. The Petitioner is granted time until 15 October 2025 to file a reply to the SCN; thereafter the Adjudicating Authority shall issue a personal hearing notice (not merely portal upload) and proceed afresh. The petition is allowed by way of remand.
The HC set aside the impugned demand order and remanded the matter to the Adjudicating Authority for fresh adjudication, finding a breach of audi alteram partem where the SCN and subsequent notices were uploaded only to the "Additional Notices" tab and the Petitioner was not afforded a real opportunity to be heard. The Petitioner is granted time until 15 October 2025 to file a reply to the SCN; thereafter the Adjudicating Authority shall issue a personal hearing notice (not merely portal upload) and proceed afresh. The petition is allowed by way of remand.
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