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 set aside the order-in-appeal dated 20.06.2025 on the ground that the appellate authority failed to consider or discuss the grounds raised in the memo of appeal, constituting a violation of the principles of natural justice and rendering the impugned order reasonless. The matter is remitted to the appellate authority for decision by a fresh, reasoned order in accordance with law. The petitioner is directed to appear before the appellate authority on 06.10.2025. The petition is disposed of by remand.
HC set aside the order-in-appeal dated 20.06.2025 on the ground that the appellate authority failed to consider or discuss the grounds raised in the memo of appeal, constituting a violation of the principles of natural justice and rendering the impugned order reasonless. The matter is remitted to the appellate authority for decision by a fresh, reasoned order in accordance with law. The petitioner is directed to appear before the appellate authority on 06.10.2025. The petition is disposed of by remand.
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