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, holding that the revisional order dated 22 July 2024 is vitiated by want of valid service of the show-cause notice dated 1 July 2024 and by a consequent breach of the principles of natural justice; accordingly, the impugned revisional order is set aside. The court confined its decision to the procedural defect and permitted the Respondent to proceed afresh with the show-cause proceedings: to effect valid service of the 1 July 2024 notice, afford the Petitioner an opportunity of hearing, and thereafter pass appropriate orders in accordance with law. The petition is allowed; the show-cause notice was not annexed to the Respondent's replies.
The HC allowed the petition, holding that the revisional order dated 22 July 2024 is vitiated by want of valid service of the show-cause notice dated 1 July 2024 and by a consequent breach of the principles of natural justice; accordingly, the impugned revisional order is set aside. The court confined its decision to the procedural defect and permitted the Respondent to proceed afresh with the show-cause proceedings: to effect valid service of the 1 July 2024 notice, afford the Petitioner an opportunity of hearing, and thereafter pass appropriate orders in accordance with law. The petition is allowed; the show-cause notice was not annexed to the Respondent's replies.
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