Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
HC held that an assessment order passed under section 143(3) read with section 144B was vitiated by breach of natural justice because the assessee was not given an effective opportunity of hearing. The authority issued a video-conferencing intimation only a few hours before the scheduled hearing, despite the assessee's request for adjournment and for a hearing after a stated date, and did not properly consider the request for reasonable time to file a reply. The assessment was set aside and the matter remanded for a fresh order after granting a meaningful opportunity of hearing, including video conferencing.
HC held that an assessment order passed under section 143(3) read with section 144B was vitiated by breach of natural justice because the assessee was not given an effective opportunity of hearing. The authority issued a video-conferencing intimation only a few hours before the scheduled hearing, despite the assessee's request for adjournment and for a hearing after a stated date, and did not properly consider the request for reasonable time to file a reply. The assessment was set aside and the matter remanded for a fresh order after granting a meaningful opportunity of hearing, including video conferencing.
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