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...
Availability of an efficacious statutory appeal against assessment orders bars resort to writ jurisdiction; failure to disclose that remedy and a misleading claim of no alternate efficacious remedy warranted dismissal, and the petitioner was granted liberty to pursue the statutory appeal. Disputed factual questions-specifically service of notice by electronic means and infringement of natural justice-are unsuitable for summary resolution in writ proceedings and do not justify bypassing the appellate scheme. All substantive contentions remain open for determination before the appellate forum.
Availability of an efficacious statutory appeal against assessment orders bars resort to writ jurisdiction; failure to disclose that remedy and a misleading claim of no alternate efficacious remedy warranted dismissal, and the petitioner was granted liberty to pursue the statutory appeal. Disputed factual questions-specifically service of notice by electronic means and infringement of natural justice-are unsuitable for summary resolution in writ proceedings and do not justify bypassing the appellate scheme. All substantive contentions remain open for determination before the appellate forum.
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