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 held that the petitioner, as an aggrieved party, was entitled to service of all material relied upon by the authority and to an opportunity to rebut; withholding of such material by the 1st respondent constituted a breach of the principles of natural justice. The court directed respondents to furnish the impugned material on the basis of which recovery of Rs. 1,79,50,000 was sought, noting that severe allegations against respondents 3-5 could not justify denying procedural fairness to the petitioner. The HC accordingly ordered early resolution of the controversy and disposed of the petition.
The HC held that the petitioner, as an aggrieved party, was entitled to service of all material relied upon by the authority and to an opportunity to rebut; withholding of such material by the 1st respondent constituted a breach of the principles of natural justice. The court directed respondents to furnish the impugned material on the basis of which recovery of Rs. 1,79,50,000 was sought, noting that severe allegations against respondents 3-5 could not justify denying procedural fairness to the petitioner. The HC accordingly ordered early resolution of the controversy and disposed of the petition.
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