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...
Retrospective cancellation of registration was found invalid because the Show Cause Notice lacked reasons supporting retrospective action and the petitioner was not placed on prior notice; that defect rendered the impugned order void. The review petition sought to reopen arguments already concluded in adjudication, but review jurisdiction cannot serve as an original hearing; therefore reopening overruled contentions was impermissible. The court found no manifest or material error on the face of the record amounting to a miscarriage of justice and accordingly dismissed the review petition.
Retrospective cancellation of registration was found invalid because the Show Cause Notice lacked reasons supporting retrospective action and the petitioner was not placed on prior notice; that defect rendered the impugned order void. The review petition sought to reopen arguments already concluded in adjudication, but review jurisdiction cannot serve as an original hearing; therefore reopening overruled contentions was impermissible. The court found no manifest or material error on the face of the record amounting to a miscarriage of justice and accordingly dismissed the review petition.
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