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 quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
The HC quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
