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 found violation of the principles of natural justice for non-consideration of the reply to notice DRC 01A and quashed the impugned assessment order insofar as it reflected the retrospective rate change from 12% to 18% under the notification. The writ petition was disposed of by setting aside the assessment on terms: the petitioner must deposit 25% of the disputed tax from the Electronic Credit Ledger within 30 days of receipt of the order. Subject to this deposit and compliance with the terms, the impugned order stands quashed; no different remedial course was warranted on the facts and circumstances before the HC.
The HC found violation of the principles of natural justice for non-consideration of the reply to notice DRC 01A and quashed the impugned assessment order insofar as it reflected the retrospective rate change from 12% to 18% under the notification. The writ petition was disposed of by setting aside the assessment on terms: the petitioner must deposit 25% of the disputed tax from the Electronic Credit Ledger within 30 days of receipt of the order. Subject to this deposit and compliance with the terms, the impugned order stands quashed; no different remedial course was warranted on the facts and circumstances before the HC.
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